CLA-2-55:OT:RR:NC:N2:349
Ms. Aricela Valerio
Barnes & Noble Inc.
1 Barnes & Noble Way
Monroe, NJ 08831
RE: The tariff classification of two amigurumi style crocheting kits from China
Dear Ms. Valerio:
In your letter dated May 28, 2025, you requested a tariff classification ruling for two amigurumi style
crocheting kits. Samples were provided and will be discarded by our office.
Item 9781936199679, “Christmas Crochet,” is a retail kit that includes red, light brown, white, and pink 100
percent acrylic staple fiber yarns presented in balls and green, dark brown, and black 100 percent acrylic
staple fiber yarns also presented without support. Each of the yarns weigh less than 125 grams. The yarns
meet the tariff definition of “put up for retail sale” found in Section XI, Note 4, Harmonized Tariff Schedule
of the United States (HTSUS). The other components included in the kit are: 1) a 72-page instruction book
that includes basic techniques for amigurumi style crocheting and step-by-step directions for an adult to
crochet 10 Christmas themed projects; 2) polyester fiberfill for stuffing the crocheted characters; 3) a metal
crochet hook; 4) a metal tapestry needle; and 5) four safety eyes. The kit includes materials needed to
crochet two projects from the book.
Item 9781936199488, “Crochet Kittens,” is a retail kit that includes red, white and grey 100 percent polyester
staple fiber yarns presented in balls and 100 percent polyester staple fiber light blue and black yarns also
presented without support. Each of the yarns weigh less than 125 grams. The yarns meet the tariff definition
of “put up for retail sale” found in Section XI, Note 4, HTSUS. The other components included in the kit
are: 1) a 72-page instruction book that includes basic techniques for amigurumi style crocheting and
step-by-step directions for an adult to crochet 10 kittens; 2) polyester fiberfill for stuffing the completed
crocheted kittens; a metal crochet hook; 4) a plastic tapestry needle; and 5) four safety eyes. The kit includes
materials needed to crochet two projects from the book.
The kits, imported in a cardboard retail box, are each considered a set for tariff purposes. The essential
character of the sets is imparted by the acrylic and polyester yarns. General Rule of Interpretation 3(b),
HTSUS, and New York Ruling Letter (NYRL) N061435, noted.
The applicable subheading for the “Christmas Crochet” will be 5511.10.0030, HTSUS, which provides for
“Yarn (other than sewing thread) of man-made staple fibers, put up for retail sale: Of synthetic staples fibers,
containing 85 percent or more by weight of such fibers: Acrylic or modacrylic.” The general duty rate will
be 7.5 percent ad valorem.
The applicable subheading for the “Crochet Kittens” will be 5511.10.0060, HTSUS, which provides for
“Yarn (other than sewing thread) of man-made staple fibers, put up for retail sale: Of synthetic staples fibers,
containing 85 percent or more by weight of such fibers: Other.” The general duty rate will be 7.5 percent ad
valorem.
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 subheadings 5511.10.0030 and 5511.10.0060, 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 subheadings
5511.10.0030 and 5511.10.0060, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 5511.10.0030 and 5511.10.0060, 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., 9903.88.03, in addition to subheadings 5511.10.0030 and 5511.10.0060, 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/.
We note that the kits contain polyester fiberfill from China and may be subject to antidumping duties and
countervailing duties (“AD/CVD”) for polyester staple fiber from China (A-570-905 or A-570-060 and/or
C-570-061). When there is a question as to whether merchandise is subject to an antidumping or
countervailing duty order or considered to be defined by the scope of an order, such a determination is
governed by the U.S. Department of Commerce’s International Trade Administration (“Commerce”).
Commerce issues scope rulings to determine whether merchandise which is in commercial production is
covered by the scope of an antidumping or countervailing duty order. Commerce’s scope rulings are separate
and distinct from decisions issued by CBP regarding tariff classification and country of origin for purposes
such as duty assessment and marking.
To seek a scope ruling, please visit the website of Commerce’s International Trade Administration. A guide
to seeking a scope ruling can be found at https://access.trade.gov/help
/Scope_Ruling_Guidance_(4.1.2022).pdf. A list of current AD/CVD investigations at the United States
International Trade Commission can be viewed on its website at http://www.usitc.gov. Additionally,
messages sent by Commerce to CBP regarding AD/CVD cash deposits and liquidation can be searched using
ACE or CBP’s search tool at https://trade.cbp.dhs.gov/ace/adcvd/adcvd-public/#.
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 Kim Wachtel at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division