CLA-2-73:OT:RR:NC:N1:164
Ivette Ocasio
Ralph Lauren
100 Metro Boulevard
Nutley, NJ 07110
RE: The tariff classification of shot glass and flask sets from India
Dear Ms. Ocasio:
In your letter dated June 5, 2025, you requested a tariff classification ruling regarding shot glass and flask
sets from India. Product information and digital photographs were submitted with your request.
The first items under consideration are described as shot glasses and a holder to be imported and sold as a set.
Included in the set are 6 stainless steel shot glasses of 2.7 ounce capacity and weighing 25 grams each.
Accompanying the shot glasses is a holder of 100% cow leather lined with 100% polyester. The holder is
8.65 centimeters (cm) in height, weighs 140 grams, and features an extending strap that fastens the lid to the
body with a metal button. Examination of the submitted picture shows that the leather is ornately decorated,
robust, and sized to fit the accompanying shot glasses.
The next items under consideration are described as a stainless steel flask and a holder to be imported and
sold as a set. The stainless steel flask has a capacity of 6 ounces, weighs 152 grams, and features a spherical
cap. The holder of 100% cow leather measures 14 cm in height by 11 cm in width, contains a 3 cm gusset,
and weighs 48 grams. The holder features a loop which is placed around the mouth of the flask to secure it in
place with a metal button. Examination of the submitted picture shows that the leather is ornately decorated,
robust, and sized to hold the accompanying flask.
Classification under the Harmonized Tariff Schedule of the United States is in accordance with the General
Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods will be determined according
to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that
the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not
otherwise require, the remaining GRIs 2 through 6 will then be applied in order.
The Explanatory Notes, which constitute the official interpretation of the HTSUS at the international level,
state in Note X to GRI 3(b) that the term “goods put up in sets for retail sale” means goods that: (a) consist of
at least two different articles which are, prima facie, classifiable in different headings; (b) consist of articles
put up together to meet a particular need or carry out a specific activity; and (c) are put up in a manner
suitable for sale directly to users without repacking. Based on the information provided, both sets under
consideration meet these criteria and will be considered “goods put up in sets for retail sale.” GRI 3(b)
provides that goods put up in sets for retail sale shall be classified as if they consisted of the material or
component which gives them their essential character.
Although the shot glasses and flask are functionally predominant, the cow leather holders are of high quality,
ornately decorated, and are significantly more expensive than the shot glasses and flasks, respectively. As a
result, it is the opinion of this office that neither the shot glasses and flask nor the leather holders impart the
essential character of the sets. Therefore, classification will be in accordance with GRI 3(c) which requires, in
part, that the item be classified in the heading which occurs last in numerical order among those which merit
equal consideration. In the first set, the shot glasses appear last in the HTSUS. In the second set, the flask
appears last in the HTSUS.
The applicable subheading for the shot glass and holder sets will be 7323.93.0080, HTSUS, which provides
for Table, kitchen or other household articles and parts thereof, of iron or steel; iron or steel wool; pot
scourers and scouring or polishing pads, gloves and the like, of iron or steel: Other: Of stainless steel: Other.
The general rate of duty will be 2% ad valorem.
The applicable subheading for the flask and holder sets will be 7326.90.3500, HTSUS, which provides for
Other articles of iron or steel: Other: Other: Containers of a kind normally carried on the person, in the
pocket or in the handbag. The general rate of duty will be 7.8% ad valorem.
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter
99, headings 9903.81.89 and 9903.81.90. Products provided by heading 9903.81.91 will be subject to a duty
of 50 percent upon the value of the steel content. At the time of entry, you must report the Chapter 99
heading applicable to your product classification, i.e. 9903.81.90, in addition to subheadings 7323.93.0080
and 7326.90.3500, HTSUS. Derivative iron or steel products processed in another country from steel articles
melted and poured in the United States, provided for in heading 9903.81.92, are not subject to the additional
ad valorem duties. Please note that derivative steel products admitted to a U.S. foreign trade zone under
“privileged foreign status” before March 12, 2025, and entered for consumption on or after March 12, 2025,
may be subject to additional duties under heading 9903.81.93, HTSUS.
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. Your product falls within an excepted
subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.01.33, in addition to subheadings 7323.93.0080 and 7326.90.3500, 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
(C.F.R.), 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 C.F.R. 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 Paul Taylor at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division