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 helmet accessories from China
Dear Ms. Charron:
In your letter dated August 14, 2025, you requested a tariff classification ruling. Photographs of three
variations of the subject merchandise were submitted with your request.
The article identified as the “Sidekick Cold Weather Kit” is a bicycle helmet accessory designed exclusively
for use with the Ozmo Sidekick Children’s bicycle helmet. The kit consists of a knit mesh polyester fabric
top cover, and a pair of detachable polyester fabric ear covers. The top cover is specifically designed to attach
to the inner surface of the helmet shell by means of Velcro. The padded ear covers are detachable with
internal plastic inserts designed to fit into a dedicated housing built into the underside of the helmet, where
they lock into place with a click mechanism. The Cold Weather kit is imported in two sizes, XXS and XS.
The applicable subheading for the Sidekick Cold Weather Kit will be 6507.00.0000, Harmonized Tariff
Schedule of the United States, HTSUS, which provides for “Headbands, linings, covers, hat foundations, hat
frames, peaks (visors) and chin straps, for 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 6507.00.0000, 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 6507.00.0000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 6507.00.0000, 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 6507.00.0000, 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