CLA-2-39:OT:RR:NC:N4:422
Ms. Jacquelyn Votra
Trans-Border Global Freight Systems
2103 Route 9
Round Lake, NY 12156
RE: The tariff classification of a plastic baby bottle, 3-in-1 starter pack, and accessory pack from China
Dear Ms. Votra:
In your letter dated June 16, 2025, you requested a tariff classification ruling, on behalf of your client,
Babygami Co. Photographs, and the product website of items were submitted with your ruling request.
The items under consideration are identified as a “single baby bottle,” product number C-WM1182-01, a
“3-in-1 starter pack, ” product number 00860014272226 UPC-A SST1, and an “accessory pack,” product
number C-MCD-WM1182-02.
The “single baby bottle,” product number C-WM1182-01, includes a collapsible plastic baby bottle, a
silicone nipple, and a plastic cap. A carabiner is attached on the side of the plastic baby bottle. The volume
capacity of the bottle is 8 ounces.
The “3-in-1 starter pack,” product number 00860014272226 UPC-A SST1, includes a collapsible plastic
baby bottle, a silicone nipple, a plastic perforated snack insert, a plastic snack cup cover, and a plastic cap. A
carabiner is attached on the side of the plastic baby bottle. The volume capacity of the bottle is 8 ounces.
The “accessory pack,” product number C-MCD-WM1182-02, includes a silicone nipple top, a plastic cap, a
plastic snack perforated insert, and a plastic snack cup cover. The accessory pack is designed to be used with
the collapsible plastic baby bottle.
As per our telephone conversation on July 11th, 2025, you requested three separate classifications regarding
the above three items.
The first item is a “3-in-1 starter pack,” 00860014272226 UPC-A SST1, and an “accessory pack,” product
number C-MCD-WM1182-02, which will be imported together for retail sale. The “3-in-1 starter pack”
consists of a collapsible plastic baby bottle, a silicone nipple, a plastic perforated snack insert, a plastic snack
cup cover, and a plastic cap. The accessory pack consists of a silicone nipple top, a plastic cap, a plastic
perforated snack insert, and a plastic snack cup cover.
The second item is a single baby bottle, which includes a collapsible plastic baby bottle, a silicone nipple,
and a plastic cap.
The third item is an accessory pack, which includes a silicone nipple top, a plastic cap, a plastic snack
perforated insert, and a plastic snack cup cover.
This items are considered goods consisting of different components classified in two or more headings within
the meaning of General Rule of Interpretation (GRI) 3. The 3-in-1 starter pack and the accessory pack will
both be imported together for retail sale. The essential character is imparted by the plastic baby bottle. The
baby bottle performs the primary role of providing a vessel to hold the liquid that the baby will drink. The
other articles in the 3-in-1 starter pack and the accessory pack perform subordinate roles in relation to the
bottles. Therefore, it is the opinion of this office that the baby bottle provides the item with the essential
character within the meaning of GRI 3(b).
For the single baby bottle, the essential character is imparted by the plastic baby bottle. The baby bottle
performs the primary role of providing a vessel to hold the liquid that the baby will drink. Therefore, it is the
opinion of this office that the baby bottle provides the item with the essential character within the meaning of
GRI 3(b).
For the accessory pack, it is the opinion of this office that the silicone nipple top provides the item with the
essential character within in the meaning of GRI 3(b).
The applicable subheading for the “3-in-1 starter pack,” 00860014272226 UPC-A SST1, imported together
and sold for retail sale with the “accessory pack,” product number C-MCD-WM1182-02, and the “single
baby bottle,” product number C-WM1182-01,” will be 3924.10.4000, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for tableware, kitchenware…of plastics: tableware and kitchenware:
other. The rate of duty will be 3.4 percent ad valorem.
The applicable subheading for the “accessory pack,” product number C-MCD-WM1182-02, will be
3924.90.0500, HTSUS, which provides for…other household articles…of plastics: other: nursing nipples and
finger cots. The rate of duty will be 3.1 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 3924.10.4000 and 3924.99.0500, 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. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other
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. 9903.01.63, in addition to
subheadings 3924.10.4000 and 3924.99.0500, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 3924.90.0500, 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 subheading 3924.90.0500, 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.
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 Dana L. Giammanco at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division