LA-2-95:OT:RR:NC:N3:356
Jesse Rowlands
Absolute Cards LLC
7305 Hancock Village Drive, #114
Chesterfield, VA 23832
RE: The tariff classification of the “Pirates of the Barbary Coast Constructible Strategy Game” from
China.
Dear Mr. Rowlands:
In your letter submitted on October 23, 2025, you requested a tariff classification ruling.
Photographs and a description of a retail booster box containing 36 sealed game packs of the “Pirates of the
Barbary Coast Constructible Strategy Game,” item number WZK6074, was submitted with your inquiry.
Each pack consists of 7 plastic styrene cards with die-cut ship pieces, plastic coins, a plastic die and game
rules. Ships are assembled from the plastic cards to form tabletop models. “Pirates of the Barbary Coast” is
a constructible strategy game where players build and command fleets of ships to find treasure and battle
opponents. The objective of the game is to collect the most gold and treasure. The game is designed for
children 8 years of age and older.
The binding ruling request seeks classification of the “Pirates of the Barbary Coast Constructible Strategy
Game” (booster boxes, sealed booster packs, and promotional cards) in subheading 9705.29.0000
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Collections and collectors’
pieces of zoological, botanical, mineralogical, anatomical, or paleontological interest: Other.” We disagree.
The subject merchandise is more specifically provided for elsewhere in the tariff schedule.
The applicable subheading for the “Pirates of the Barbary Coast Constructible Strategy Game,” item number
WZK6074, will be 9504.90.9080, HTSUS, which provides for “Video game consoles and machines, table or
parlor games, including pinball machines, billiards, special tables for casino games and automatic bowling
equipment, amusement machines operated by coins, banknotes, bank cards, tokens or by any other means of
payment: Other: Other: Other: Other.” 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 10 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 9504.90.9080, 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 from all countries
will be subject to an additional 10 percent ad valorem rate of duty. 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
9504.90.9080, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 9504.90.9080 HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15,
in addition to subheading 9504.90.9080, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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/current.
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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division