CLA-2-49:OT:RR:NC:N4:434
Aricela Valerio
Barnes & Noble Inc
1 Barnes & Noble Way
Monroe, NJ 08831
RE: The tariff classification of a knot tying-in kit from China
Dear Ms. Valerio:
In your letter dated May 2, 2025, you requested a tariff classification ruling. A detailed description and
photos were provided for our review, along with a sample.
The item under consideration is a knot tying kit, which includes four ropes packaged together with a
paperback book titled, "The Handy Box of Knots: Useful knots for every situation indoors & out," by knot
expert Randy Penn. The braided rope is of a high quality and is durable. Three ropes have a diameter of
4mm and a length of 36 inches, and one rope has a diameter of 13mm and a length of 32 inches. The book
contains 288 pages with step-by-step instructions for more than 100 essential knots, as well as dozens of
games and exercises for honing newfound skills. The book measures approximately 7.12" by height and
4.75" by width.
The book and the rope meet the definition of a set within the context of General Rule of Interpretation 3(b)
(GRI 3(b)). Sets are classified according to the component, or components taken together, which can be
regarded as conferring on the set as a whole its essential character. In this case, The “Handy Box of Knots”
book confers the essential character.
The applicable subheading for the knot tying-kit will be 4901.99.0093, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for “Printed books, brochures, leaflets and similar printed matter,
whether or not in single sheets: Other: Other: Other: Other: Other: Containing 49 or more pages each
(excluding covers).” The rate of duty will be Free.
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 at https://hts.usitc.gov/.
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. ?Merchandise classifiable under subheadings 4901.99.0093 HTSUS, constitutes ?any information or
informational materials? encompassed by 50 U.S.C. ? 1702(b)(3). ?Accordingly, such merchandise is exempt
from additional duties under Executive Order 14195 pursuant to heading 9903.01.22, HTSUS.
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. ?Regarding articles the product of China
and Hong Kong that are ?informational materials,? including goods classifiable in Chapter 49, HTSUS, such
merchandise is exempt from additional duties under Executive Order 14257 pursuant to heading 9903.01.31,
HTSUS. ?The books are also exempt by virtue of inclusion in Annex II to Executive Order 14257, under
9903.01.32, HTSUS.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 4901.99.0093, 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, 9903.88.15, in
addition to subheadings 4901.99.0093, 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, 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/remedies/301-certain-products-china, respectively.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. ?This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). ?This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. ?In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
?Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
Regulations (19 CFR 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, please contact
National Import Specialist Charlene Miller at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division