CLA-2-63:OT:RR:NC:N3 351
Ms. Donna Huggins
Franco Manufacturing Co., Inc.
555 Prospect Street
Metuchen, NJ 08840
RE: The tariff classification of a pillow-like article in the form of a ribbon bow with a detachable plushie
from China
Dear Ms. Huggins:
In your letter dated December 1, 2025, you requested a tariff classification ruling. A sample of the product
was provided to this office and will be returned as per your request.
The sample, described as a “Detachable Mini Cuddle Pillow with Bow Pillow Set,” consists of a pillow-like
article designed and shaped to resemble a ribbon bow and a detachable plushie. The bow-shaped pillow-like
article is a home decoration intended to be placed on a bed and the plushie is intended to be hung on a
backpack or played with. The bow is composed of 100 percent polyester knit dyed pink fabric and stuffed
with 100 percent polyester fiberfill. The bow, measuring 24 inches in length by 14 inches in width, features
the words “Hello Kitty” in cursive on one of its tails (the hanging ends of the bow). A detachable Hello Kitty
mini plushie is attached to the center loop of the bow by a plastic snap closure sewn to its back. The plushie
is composed of 100 polyester knit dyed pink velboa fabric and stuffed with 100 percent polyester fiberfill.
The plushie features two embroidered eyes, a nose, three whiskers on each side of its face, and a 3-D bow
attached near the left ear. The plushie measures 4 ¾ inches in length by 3 ¼ inches in width. You state that
the bow-shaped pillow and detachable plushie will not be imported separately.
The Explanatory Notes (ENs) to the Harmonized Tariff Schedule of the United States (HTSUS) constitute the
official interpretation of the tariff at the international level. 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 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 users without repacking (e.g., in boxes or
cases or on boards).” Sets are classified according to the component, or components taken together, which
can be regarded as conferring on the set its essential character.
The “Detachable Mini Cuddle Pillow with Bow Pillow Set” consists of a pillow-like article shaped like a
ribbon bow and a detachable Hello Kitty mini plushie. Both the bow and the plushie are classifiable under
the same heading. Therefore, the items fail to fulfill the requirements of (a) above. As such, we find that
bow and plushie are not considered sets for retail sale for classification purposes.
You have suggested that the “Detachable Mini Cuddle Pillow with Bow Pillow Set,” should be classified
under subheading 9503.00.0073, HTSUS, which provides for “Tricycles, scooters, pedal cars, and similar
wheeled toys…dolls, other toys…puzzles of all kinds; parts and accessories thereof… ‘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.” We disagree. These products offer no manipulative play value. In our view, these items
are primarily meant for display and used for decoration rather than for play or amusement.
The applicable subheading for the pillow-like article shaped like a ribbon bow and detachable Hello Kitty
mini plushie will be 6307.90.9891, HTSUS, which provides for “Other made up articles, including dress
patterns: Other: Other: Other: Other: Other.” The duty rate will be 7 percent ad valorem.
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)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division