OT:RR:NC:N3:356
Jong Whi Pak
OEC Group New York
133-33 Brookeville Boulevard, Suite 306
Rosedale, NY 11422
RE: The classification and country of origin of baby doll sets from Indonesia
Dear Mr. Pak:
In your letter dated June 2, 2025, you requested a country of origin ruling on behalf of your client, Madame
Alexander Doll Company (2018) LLC.
The articles under consideration are baby doll sets with accessories proportionally sized and designed to fit
the dolls. Photographs, descriptions, and production information for Baby Doll Sets 20337 and 20257 were
submitted with your inquiry.
Baby Doll Set 20337 is comprised of a baby doll and its accessories. The accessories consist of a plastic cup,
fork, spoon, pacifier, box, plate, and chair, small plastic foods, baby doll apparel, and a towel. Packaging, a
paper insert, and labels are also included.
Baby Doll Set 20257 is comprised of a baby doll and its accessories, which include a plastic pacifier and
baby bottle. Packaging, paper inserts, and labels are also included.
Baby Doll Sets 20337 and 20257 are principally designed for the amusement of children under 3 years of
age.
In your letter, you suggest that the subject sets are classifiable under 9503.00.0071, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for dolls intended for use by persons under 3 years
of age. We agree.
CLASSIFICATION:
In accordance with General Rule of Interpretation (GRI) 3(b), HTSUS, the applicable subheading for Baby
Doll Sets 20337 and 20257 will be 9503.00.0071, HTSUS, which provides for “Tricycles, scooters, pedal
cars and similar wheeled toys… dolls, other toys…: ‘Children’s products’ as defined in 15 U.S.C. § 2052:
Other: Labeled or determined by importer as intended for use by persons: Under 3 years of age.” The column
one, general rate of duty will be free.
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
9503.00.0071, HTSUS, listed above.
COUNTRY OF ORIGIN - LAW AND ANALYSIS:
With regard to your request for the appropriate country of origin of Baby Doll Sets #20337 and #20257, 19
C.F.R. § 134.1(b) provides in pertinent part as follows: Country of origin means the country of manufacture,
production, or growth of any article of foreign origin entering the United States. Further work or material
added to an article in another country must effect a substantial transformation in order to render such other
country the “country of origin” within the meaning of this part.
As stated in HQ 735009, dated July 30, 1993, “The country of origin is the country where the article last
underwent a ‘substantial transformation’ that is, processing which results in a change in the article's name,
character, or use.” The test for determining whether a substantial transformation will occur is whether an
article emerges from a process with a new name, character, and use, different from that possessed by the
article prior to processing. See Texas Instruments Inc. v. United States, 69 C.C.P.A. 151 (1982). This
determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16
C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). In order to determine whether a substantial
transformation occurs when components of various origins are assembled into completed products, all factors
such as the components used to create the product and manufacturing processes that these components
undergo are considered in order to determine whether a product with a new name, character, and use has been
produced. No one factor is decisive, and assembly operations that are minimal will generally not result in a
substantial transformation.
With respect to Doll Sets 20337 and 20257, you state the following:
The dolls’ hands, legs, and inner materials, including filling, are manufactured in Indonesia from materials
sourced from various countries.
The heads of both dolls are made in China from materials sourced from Korea.
The cutting and sewing of the materials for the doll bodies, and all assembly operations, including the
attachment of the doll heads to the bodies, take place in Indonesia. Therefore, the country of origin of the
dolls is Indonesia.
Further, all of the accessories included in each set are made in Indonesia.
Based on the information submitted, the country of origin of Baby Doll Sets 20337 and 20257 is Indonesia.
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 Maryalice Nowak at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division