CLA-2-95:OT:RR:NC:N3:356
Emily Seedle
Spreetail, LLC
2125 Transformation Drive, Suite 3200
Lincoln, NE 68521
RE: The tariff classification of pedal cars from China
Dear Ms. Seedle:
In your letter dated October 3, 2025, you requested a tariff classification ruling. Descriptions of various
models of Hauck pedal cars and photographs of their retail packaging, which include images of each item,
were included with your inquiry.
The Hauck Cyclone S.W.A.T. Pedal Go-Kart (item #90609) is propelled by means of foot pedals. It features
a steel frame, plastic wheels, a 3-point steering wheel, a plastic bucket seat, and 8-ball hand brakes. It
measures 47.60” x 21.9” x 28.3”, weighs 30.86 pounds, and has a maximum weight capacity of 121 pounds.
It is designed principally for the amusement of children between the ages of 4 and 10.
The Hauck Speedster Pedal Go-Kart (item #s 90301 “blue,” 90302 “Fire Rescue,” and 90802 “black/red”) is
propelled by means of foot pedals. It features a steel frame with a plastic front plate, plastic wheels, an
adjustable plastic bucket seat, and a rear-wheel hand brake. It measures 41.7” x 20.1” x 23.3”, weighs 19.2
pounds, and has a maximum weight capacity of 110 pounds. It is designed principally for the amusement of
children between the ages of 4 and 8.
You suggest classification of the Hauck Cyclone S.W.A.T. and Speedster Pedal Go-Karts in heading 9503,
Harmonized Tariff Schedule of the United States, which provides, in relevant part, for “Tricycles, scooters,
pedal cars, and similar wheeled toys.” We agree.
The applicable subheading for the Hauck Cyclone S.W.A.T. and Speedster Pedal Go-Karts (item #s 90609,
90301, 90302, and 90802) will be 9503.00.0073, HTSUS, which provides for “Tricycles, scooters, pedal cars,
and similar wheeled toys… ‘Children’s products’ as defined in 15 U.S.C. § 2052: Other: Labeled or
determined by importer as intended for use by persons: 3 to 12 years of age.” The column one, 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 9503.00.0073, 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 9503.00.0073, 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/.
Additionally, based on the photographs included in your submission, we note that the retail packaging of the
Speedster Pedal Go-Karts is marked “Designed in Germany.” 19 Code of Federal Regulations (CFR) 134.46
states, in relevant part:
In any case in which… the name of any foreign country or locality other than the country or locality in which
the article was manufactured or produced appear on an imported article or its container, and those… names
may mislead or deceive the ultimate purchaser as to the actual country of origin of the article, there shall
appear legibly and permanently in close proximity to such… name, and in at least a comparable size, the
name of the country of origin preceded by “Made in,” “Product of,” or other words of similar meaning.
Please be aware that in order to satisfy the “close proximity” requirement of 19 CFR 134.46, the actual
country of origin must generally appear on the same side(s) or surface(s) on which the name or locality other
than the actual country of origin appears.
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 Maryalice Nowak at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division