CLA-2-95:OT:RR:NC:N4:424
Ethan Osheroff
Roll & Harris LLP
2121 Avenue of the Stars, Suite 800
Los Angeles, CA 90067
RE: The tariff classification of the “Atomic Northport 3 in 1 Air Hockey, Table Tennis, & Dining Table
Combo” with 2 storage benches from China.
Dear Mr. Osheroff:
In your letter dated March 3, 2026, you requested a tariff classification ruling on behalf of your client,
Escalade Sports.
Photographs and a description of the “Atomic Northport 3 in 1 Air Hockey, Table Tennis, & Dining Table
Combo” with 2 storage benches were submitted with your request. The electric air hockey table measures
approximately 84" x 47" x 31, has an integrated AC-powered blower and is constructed primarily of medium
density fiberboard (MDF). The game table features a versatile, 0.5" thick, removable overlay that seamlessly
converts the unit into a ping-pong or dining surface. The air hockey’s built-in blower system creates a
cushion of air that minimizes friction, ensuring the puck glides effortlessly across the play surface. The table
includes 4 pucks, 4 pushers, a net, 2 paddles, and 2 ping pong balls. Each storage bench is also made
primarily of MDF, has an upholstered seat, and measures approximately 67” x 13” x 19”.
You suggest classification of the subject merchandise under subheading 9504.90.4000, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for "Articles for arcade, table or parlor games…:
Other: Game machines, other than those operated by coins, banknotes (paper currency), discs or similar
articles; parts and accessories thereof." We agree in part.
At its core, this is an electronic air hockey table, featuring a removable top that converts into a dining or table
tennis surface. The essential character of this combination unit is determined by the irremovable electronic
air hockey table integrated into the frame; the removable top serving as a dining or table tennis surface is
secondary.
To determine if the bundled benches and game table qualify as a set for classification, we apply GRI 3(b) and
the corresponding Explanatory Notes (EN). Under this rule, a "set put up for retail sale" must consist of at
least two different items classifiable under separate headings, packaged together to fulfill a specific activity,
and ready for direct sale without repacking. Such sets are classified based on the component that provides
their essential character.
In order to determine if the bundled benches and game table qualify as a single set for classification purposes,
we refer to EN X to General Rule of Interpretation (GRI) 3(b) which 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 as
a whole its essential character.
The items under consideration consist of two articles classifiable under separate headings. They are
packaged for retail sale. Therefore, they fulfill the requirements of (a) and (c) above. However, we believe
that they fail (b). The benches are not used during game play, consequently they will be classified separately
from the electronic air hockey game.
The applicable subheading for the “Atomic Northport 3-in 1 Air Hockey, Table Tennis, & Dining Table
Combo,” will be 9504.90.4000, HTSUS, which provides for "Articles for arcade, table or parlor games…:
Other: Game machines, other than those operated by coins, banknotes (paper currency), discs or similar
articles; parts and accessories thereof." The rate of duty will be free.
The applicable subheading for the storage benches will be 9401.61.6011, HTSUS, which provides for “Seats
(other than those of heading 9402), whether or not convertible into beds, and parts thereof: Other seats, with
wooden frames: Upholstered: Other: Other household.” The rate of duty will be free.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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 Irene Tsiavos at [email protected]
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division