CLA-2-51:OT:RR:NC:N2:349
Ms. Rachel Bath
Bergin and Bath, Co.
4a Hardy House, Northbridge Road
Berkhamsted HP4 1EF
United Kingdom
RE: The tariff classification of a needle-felting craft kit from the United Kingdom
Dear Ms. Bath:
In your letter dated August 13, 2025, you requested a tariff classification ruling. A sample was provided with
the request and will be retained for training purposes.
SKU NF-HEDGE (GTIN 5065018311031), described as a “Needle Felting Kit Hedgehog” under the Bergin
& Bath™ brand, includes approximately 25 grams of carded wool fiber in assorted colors: brown, greyish
brown, light pink, black and white; one steel felting needle; two small glossy black metal eye pins; and
step-by-step photographic instruction cards on how to create a small, felted hedgehog figure. You state that
once the felted creature is created, the finished item is decorative with no practical utility beyond display. The
kit is packaged together for retail sale and marketed to adults and older teens as a creative amusement
activity.
You suggest the needle felting kit is classified under subheading 9503.00.0090, Harmonized Tariff Schedule
of the United States (HTSUS), which provides for “Tricycles, scooters, pedal cars and similar wheeled
toys… dolls, other toys… puzzles of all kinds; parts and accessories thereof… Other.” We disagree. Once
completed, the item, a felted hedgehog figure, features sharp, barbed needles. Therefore, it is not designed or
intended for manipulative play or repeated handling. Moreover, the level of expertise needed to follow the
instructions exceeds that of educational toys.
The Explanatory Notes (ENs) to the HTSUS constitute the official interpretation of the tariff at the
international level. GRI 3(b) provides that goods put up in sets for retail sale shall be classified as if they
consisted of the material or component that gives them their essential character. EN X to General Rule of
Interpretation (GRI) 3(b) provides: “For the purposes of this Rule, the term “goods put up in sets for retail
sale” shall be taken to mean goods which:
(a) consist of at least two different articles which are, prima facie, classifiable in different headings;
(b) consist of products or articles put up together to meet a particular need or carry out a specific
activity; and
(c) are put up in a manner suitable for sale directly to end users without repacking (e.g., in boxes or
cases or on boards).
The needle felting kit consists of carded wool fiber (heading 5105), and a steel needle and metal eye pins of
Chapter 73, HTSUS. The needle felting kit consists of at least two different articles that are, prima facie,
classifiable in different headings put up together to carry out a specific activity, i.e., making a craft. Further,
the articles are put up in a manner suitable for sale directly to users without repacking. Therefore, the kit in
question meets the term "goods put up in sets for retail sale." GRI 3(b) states, in part, that goods put up in
sets for retail sale, which cannot be classified by reference to GRI 3(a), are to be classified as if they
consisted of the component that gives them their essential character. In this case, we have determined that
the carded wool fibers impart the essential character to the needle felting kit set.
The applicable subheading for the “Needle Felting Kit Hedgehog” will be 5105.10.0000, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for carded wool. The rate of duty will be 6.5 cents
per kilogram plus 5.3 percent ad valorem.
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 the United
Kingdom 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. 9903.02.66, in addition to
subheading 5105.10.0000, 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 Kimberly Wachtel at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division