CLA-2-63:OT:RR:NC:N3:351
Ms. Jessica Rowe
Blue Q
703 West Housatonic Street
Pittsfield, MA 01201
RE: The tariff classification of an embroidered bag charm from Taiwan
Dear Ms. Rowe:
In your letter dated November 10, 2025, you requested a tariff classification ruling. A sample of the
embroidered bag charm was provided with your request and will be retained for training purposes.
Item #BC100, described as a “Boss Kitty Bag Charm” is an embroidered textile charm designed to hang on a
handbag or backpack. The charm is composed of two layers of 100 percent polyester woven twill fabric
embroidered with 100 percent rayon filament yarn. The two layers of fabric are glued together. The
embroidered charm depicts a cat riding a horse with the word “Boss Kitty” along the bottom of the front and
an embroidered logo “Blue Q” on the back. The charm measures 3 ¼ inches in length by 2 ¾ inches in
width and features an iron eyelet, a jump ring, and a slit ring.
The bag charm is a composite good consisting of a made up textile fabric (heading 6307) and a metal
keychain (heading 7326). General Rule of Interpretation (GRI) 1, Harmonized Tariff Schedule of the United
States (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. In this case, we find the essential character of the charms to be the textile
component. The textile component provides aesthetic appeal and marketability, while the jump ring and slit
ring are intended to facilitate the connection between the charm and a handbag. As such, the jump ring and
split ring are subservient to the charm and not principally intended for holding keys during routine use.
You have suggested that the bag charm should be classified under subheading 6307.90.9891, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for “Other made up articles, including dress
patterns: Other: Other: Other: Other: Other.” We agree. The rate of duty will be 7 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 Taiwan will be
subject to an additional ad valorem rate of duty of 20 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.60, in addition to subheading
6307.90.9891, 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 Kristine Dodge at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division