CLA-2-95:OT:RR:NC:N4:424
John Navarrete
Broken Forge Games
18703 Millhollow
San Antonio, TX 78258
RE: The tariff classification of the “Broken Empires” game from China.
Dear Mr. Navarrete:
In your letter submitted on April 22, 2025, you requested a tariff classification ruling on behalf of your client
Evil Baby Entertainment LLC.
Photographs and a description of the “Broken Empires” role playing game (RPG) starter set, based on a
trilogy of fantasy novels by Mark Lawrence, was submitted with your inquiry. The item is a boxed starter set
containing printed materials and components required to learn and play a fantasy role-playing game. The
product includes a Quick Start Rules booklet, a “Witches of Grimdale” booklet, 4 character sheets, a
character sheet pad, 6 double-sided 11” x 17” encounter maps, a full-color annotated world map of “The
Broken Empires,” tokens, and 10 custom die. The game is designed for children 12 years of age and older.
The applicable subheading for the “Broken Empires” RPG starter set will be 9504.90.9080, HTSUS, which
provides for Video game consoles and machines, articles for arcade, table or parlor games, including pinball
machines, bagatelle, billiards and special tables for casino games; automatic bowling alley equipment; parts
and accessories thereof: Other: Other: Other: Other. The rate of duty will be Free.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 9504.90.9080, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, 9903.01.25, in addition to subheading
9504.90.9080, HTSUS, listed above.
Pursuant to U.S. Note 31 (b) to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 9504.90.9080, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15,
in addition to subheading 9504.90.9080, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS
and the accompanying duty rates are provided on World Wide Web at https://hts.usitc.gov/current.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents
filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact
National Import Specialist Roseanne Murphy at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division