CLA-2-49:OT:RR:NC:N5:130
Mr. Louis Shoichet
Sandler, Travis & Rosenberg, P.A.
675 Third Avenue - Suite 2425
New York, NY 10017
RE: The tariff classification of books from China
Dear Mr. Shoichet:
In your letter, dated June 3, 2025, you requested a binding classification ruling on behalf of your client, 1616
Holdings, Inc. The request addressed multiple books. Product information and photos were submitted for our
review.
The products under consideration are five books, including “Pokemon Advanced Coloring” book, “Horror
Movies Coloring Book”, “Nostalgic Recipes from the ‘50s, ‘60s, ‘70s, and ‘80s”, “Dad Jokes, Too”, and
“Edgar Allen Poe Classic Tales of Horror”. The two coloring books consist of pages of printed images that
are to be colored in with coloring implements. The “Pokemon Advanced Coloring” book has simple images
that a child would engage in coloring. The “Horror Movies Coloring Book” is considerably more intricate
and is centered around adult themes of horror films. The coloring books are softcover. The “Nostalgic
Recipes” book is a hardcover, spiral bound cookbook. The “Dad Jokes” and “Edgar Allen Poe” books are
hardcover, text-based books.
The applicable subheading for the “Pokemon Advanced Coloring” book will be 4903.00.0000, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for Children's picture, drawing or coloring
books. The rate of duty will be free.
The applicable subheading for the “Horror Movies Coloring Book” will be 4901.99.00, HTSUS, which
provides for Printed books, brochures, leaflets and similar printed matter, whether or not in single sheets:
Other: Other: Other: Art and pictorial books. You do not provide the value of the book, so we cannot provide
the 9th and 10th digits of the subheading. The rate of duty will be free.
The applicable subheading for the remaining books, “Nostalgic Recipes”, “Dad Jokes”, and “Edgar Allen Poe
book will be 4901.99.0070, HTSUS, which provides for Printed books, brochures, leaflets and similar printed
matter, whether or not in single sheets: Other: Other: Other: Other: Hardbound books. 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. Merchandise classifiable under subheading 4903.00.0000, 4901.99.00, and 4901.99.0070, HTSUS,
constitute “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. At the time of entry, you must report the applicable Chapter 99 subheading,
9903.01.22, in addition to subheadings 4903.00.0000, 4901.99.00, and 4901.99.0070, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” At this time products from all
countries will be subject to an additional 10 percent ad valorem rate of duty. 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. Your product falls within an excepted
subheading. At the time of entry, you must report the Chapter 99 headings applicable to your product
classification, 9903.01.31 and 9903.01.32, in addition to subheading 4903.00.0000, 4901.99.00, and
4901.99.0070, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 4901.99.00 and 4901.99.0070, 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,
i.e., 9903.88.15, in addition to subheadings 4901.99.00 and 4901.99.0070, 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, including
information on exclusions and their effective dates, 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/programs-administration/trade-remedies, respectively.
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 on the World Wide Web at https://hts.usitc.gov/current.
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 Laurel Duvall at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division