CLA-2-42:OT:RR:NC:N4:441
Scott Beatty
Nomad Goods, Inc.
1187 Coast Village Rd., Suite 638
Santa Barbara, CA 93108
RE: The tariff classification of a card holder from China
Dear Mr. Beatty:
In your letter dated May 27, 2025, you requested a tariff classification ruling. You have submitted
photographs and descriptive literature for our review.
The article at issue is a card holder. It is constructed from a rigid polycarbonate frame, wrapped in bovine
leather, and is designed to hold up to three standard-sized cards (e.g., credit cards, ID cards). The product
also incorporates an embedded magnetic array, which aligns with Apple’s MagSafe system, allowing the
item to attach magnetically to compatible iPhone models.
You have suggested that the proper classification of the card holder is under subheading 8517.62.0090,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for Machines for the reception,
conversion, and transmission or regeneration of voice, images or other data, including switching and routing
apparatus: Other. We disagree. While the addition of the tracking component may render this particular card
case more desirable than others available in the marketplace, the motivation to purchase the article is to fulfill
the needs of storing, organizing, protecting, and transporting identification or credit cards otherwise the
consumer would have purchased an individual tracker.
The applicable subheading for the card holder will be 4202.31.6000, HTSUS, which provides for articles of a
kind normally carried in the pocket or in the handbag, with outer surface of leather or of composition leather,
other. The general rate of duty will be 8 percent ad valorem.
Pursuant to U.S. Note 31 (b) to Subchapter III, Chapter 99, HTSUS, effective September 27, 2024, products
of China classified under subheading 4202.31.6000, HTSUS, unless specifically excluded, are subject to an
additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99
subheading, i.e., 9903.91.03, in addition to subheading 4202.31.6000, HTSUS, listed above.
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 4202.31.6000, 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, i.e. 9903.01.25, in addition to subheading
4202.31.6000, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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/.
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 Vikki Lazaro at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division