CLA-2-85:OT:RR:NC:N2:208

Norman Harris
NNR Global Logistics USA Inc.
21023 S Main St Unit D ,
Carson, CA 90745

RE: The tariff classification of game cartridges from Japan

Dear Mr. Harris:

In your letter dated August 25, 2025, on behalf of SEGA of America Inc., you requested a tariff classification ruling.

The merchandise under consideration is Nintendo Switch game cartridges (game cards), described as "Sonic X Shadow Generations." These Switch game cards are non-volatile flash memory storage devices. Moreover, the subject game cards can be read by a Nintendo Switch system by inserting the card into the system. As per the information provided, these game cards have 32GB of storage and contain the game's complete data, including the game code, textures, models, audio files, and any other assets required for gameplay.

The applicable subheading for the subject solid-state non-volatile storage game cartridges will be 8523.51.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Discs, tapes, solid-state non-volatile storage devices, "smart cards" and other media for the recording of sound or of other phenomena, whether or not recorded, including matrices and masters for the production of discs, but excluding products of Chapter 37: Semiconductor media: Solid-state non-volatile storage devices. The rate of duty will be free.

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 Japan will be subject to an additional ad valorem rate of duty of 15 percent. Currently, your product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.32, in addition to subheading 8523.51.0000, 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 Lisa Cariello at [email protected].
Sincerely,

(for)
Denise Faingar
Acting Director
National Commodity Specialist Division