CLA-2-54:OT:RR:NC:N2:352
Mr. Maksim Mitsilovich
Ampaxar Group Inc.
30 N Gould Street, Suite N
Sheridan, WY 82801
RE: The tariff classification of a string art kit from China
Dear Mr. Mitsilovich:
In your letter dated August 19, 2025, you requested a tariff classification ruling for a string art kit. A
complete sample kit was provided. The yarn component was sent for laboratory analysis. The remaining kit
components will be retained for reference purposes.
The subject merchandise, SKU# LS1, described as the "Let’s String Kit," consists of a multi-component arts
and crafts assembly kit packaged together for individual retail sale. It is an art kit that allows you to turn any
picture or photo into string art. The kit contains: a wooden base, measuring 19.5 × 19.5 × 0.375 inches,
pre-fitted with 240 metal nails arranged in a precise circle; a spool of monofilament nylon yarn, weighing
approximately 150 grams; a dedicated wooden spool bracket designed to attach to the main wooden base; an
adjustable wooden smartphone support stand; a structural cardboard retail container engineered to deploy as a
working artist's easel; a step-by-step instruction manual; and access to online software that processes
uploaded photos to create an interactive, voiced, step-by-step guide to complete the project. You state that
this item is not a toy and is not intended for use by children under 14 years of age.
According to the U.S. Customs and Border Protection Laboratory (CBP Laboratory) analysis, the sample
marked "Black yarn on Green Plastic Support" weighs 148.0 grams on its support. The yarn is a single,
continuous nylon monofilament that is untwisted, untextured, and not elastomeric. The CBP Laboratory
analysis indicates a cross-sectional measurement of 0.154 mm, linear density of 228 decitex (23 tex/205
denier), and tenacity of 77.53 centinewtons per tex (cN/tex).
Under the terms of Note 4 (A)(a)(i) to Section XI, Harmonized Tariff Schedule of the United States
(HTSUS), the yarn does not meet the definition of “put up for retail sale” because its gross weight on the
support exceeds 85 grams.
The "Let’s String Kit," is a composite good consisting of articles of wood (Heading 4421) and single yarn
composed of nylon monofilament (Heading 5404). General Rule of Interpretation (GRI) 1, HTSUS, states in
part that for legal purposes, classification shall be determined according to the terms of the headings, any
relative section or chapter notes and, unless otherwise required, according to the remaining GRI’s taken in
order. Goods that are, prima facie, classifiable under two or more headings, are classifiable in accordance
with GRI 3. GRI 3(a) states that the heading which provides the most specific description shall be preferred
to headings providing a more general description. However, when two or more headings refer to part only of
the items in a composite good, those headings are to be regarded as equally specific in relation to the goods,
even if one of them gives a more complete or precise description of the good. As such, they are regarded as
equally specific and classification of the composite good is to be determined by GRI 3(b) or GRI 3(c). GRI
3(b) states in part that composite goods, which cannot be classified by reference to GRI 3(a), are to be
classified as if they consisted of the component which gives them their essential character. GRI 3(c) provides
that when goods cannot be classified by reference to GRI 3(a) or 3(b), they are to be classified in the heading
that occurs last in numerical order among the competing headings which equally merit consideration. We
find that the essential character of the overall product cannot clearly be ascribed to a single material.
Therefore, pursuant to General Rule of Interpretation 3(c), HTSUS, the string art kit will be classifiable under
heading 5404, HTSUS, which occurs last in numerical order among those which equally merit consideration.
The applicable subheading for SKU #LS1, described as the “Let's String Kit,” will be 5404.19.8020, HTSUS,
which provides for “Synthetic monofilament of 67 decitex or more and of which no cross-sectional
dimension exceeds 1 mm; strip and the like (for example, artificial straw) of synthetic textile materials of an
apparent width not exceeding 5 mm: Monofilament: Other: Other: of nylon or other polyamides.” The rate of
duty will be 6.9 percent ad valorem.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
The 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/.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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 Nicole Rosso at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division