CLA-2-65:OT:RR:NC:N1:358
Casey Charron
DSGNPERKS Incorporated (DBA Ozmo)
67 35th St Unit C402
Brooklyn, NY 11232
RE: The tariff classification of a bicycle helmet from China
Dear Ms. Charron:
In your letter dated August 14, 2025, you requested a tariff classification ruling. Along with your request, you
submitted photographs and an exploded-view diagram depicting the helmet and its various components.
The item at issue, identified as “The Ozmo Sidekick,” is a bicycle helmet constructed of multiple
components. The outer shell is composed of Acrylonitrile Butadiene Styrene (ABS), while the inner shell is
composed of Expanded Polystyrene (EPS) foam. Between these layers are several shock absorbing elements
made of Ethylene Vinyl Acetate (EVA) foam and Thermoplastic Elastomer (TPE) soft rubber, leaving a
narrow air gap of approximately 2mm. The bottom edge of the EPS liner is in-molded with polycarbonate
(PC), forming a PC trim that encircles the lower circumference of the helmet.
In your request you suggest classification under subheading 6506.10.3045, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for “safety headgear of reinforced or laminated plastics.”
However, the submitted photographs and technical specifications do not demonstrate that the helmet is of
reinforced or laminated plastics. The outer shell is composed solely of ABS, lacks any additional materials
designed to provide reinforcement, and is not laminated to the EPS inner shell.
The applicable subheading for the Ozmo Sidekick helmet will be 6506.10.6045, HTSUS, which provides for
“Other headgear, whether or not lined or trimmed: Safety headgear: Other: Other: Athletic, recreational and
sporting headgear.” The general 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. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 6506.10.6045, 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 of China, Hong
Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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 6506.10.6045, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 6506.10.6045, 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 6506.10.6045, 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 Katherine Souffront at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division