CLA-2-95:OT:RR:NC:N4:424
Krista Fedon
OOLY, LLC.
5607 Palmer Way
Carlsbad, CA 92010
RE: The tariff classification of a shrink art kit from China.
Dear Krista Fedon:
In your letter submitted on May 12, 2025, you requested a tariff classification ruling.
Photographs and a description of the “161-166 Shrink-Its! D.I.Y. Shrink Art Kit- Deluxe” were submitted
with your inquiry.
The product is described as a do it yourself shrink art kit which consists of 48 pre-cut shrinking plastic
charms, 15 colored ball chains, 2 colored cords, 8 paint markers and 1 instruction sheet. Users will color
each of the shrinking plastic charms using the markers on the textured side of the charm. The charms will
then be placed into an oven, or toaster oven for 1 to 3 minutes, which will result in the charms shrinking up to
50% of their original size. Once the charms have completely cooled down the user can use the ball chain
provided to create keychains. Cords can be cut down to desired length to hang the charms onto backpacks,
zipper pulls and more. The Shrink-Its! kit is principally designed for the amusement of children 6 years of
age and older.
The applicable subheading for the “161-166 Shrink-Its! D.I.Y. Shrink Art Kit- Deluxe” will be 9503.00.0073,
Harmonized Tariff Schedule of the United States (HTSUS). which provides for “Tricycles, scooters, pedal
cars, and similar wheeled toys…dolls, other toys…puzzles of all kinds; parts and accessories thereof…
‘Children’s products’ as defined in 15 U.S.C. § 2052: Other: Labeled or determined by importer as intended
for use by persons: 3 to 12 years of age.” 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 9503.00.0073, 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. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 10 percent. Products from all other
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, 9903.01.63, in addition to subheading
9503.00.0073, HTSUS, listed above.
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.
Importations of this product may be subject to the provisions of Section 133 of the Customs Regulations if
they copy or simulate a registered trademark, trade name or copyright recorded with U.S. Customs and
Border Protection. If you are an authorized importer of the product we recommend notifying your local
Customs office prior to importation.
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 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, please contact
National Import Specialist Roseanne Murphy at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division