CLA-2-42:OT:RR:NC:N4:441
Kristen Fannon
UWL, Inc.
1340 Depot Street
Rocky River, OH 44116
RE: The tariff classification of a tracker pouch from China
Dear Ms. Fannon:
In your letter dated August 8, 2025, you requested a tariff classification ruling on behalf of your client,
Neverlost LLC. You have submitted photographs and descriptive literaure for our review.
The article at issue, which you have referred to as the GPS Pocket Buddy, is a textile pouch designed to hold
an air tag or similarly sized tracking device. You have indicated that the pouch is constructed of nylon, which
is a man-made fiber. It features overlapping front closure and a mesh adhesive that will allow to be attached
to a variety of articles.
The applicable subheading for the pouch will be 4202.92.9100, Harmonized Tariff Schedule of the United
States (HTSUS), which provides for other containers and cases, with outer surface of sheeting of plastic or of
textile materials, other, other, with outer surface of textile materials, of man-made fibers (except jewelry
boxes of a kind normally sold at retail with their contents). The general rate of duty will be 17.6 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 subheading 4202.92.9100, 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, and subheading 4202.92.9100,
HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 4202.92.9100, 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 subheading 4202.92.9100, 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
(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 Vikki Lazaro at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division