CLA-2-95:OT:RR:NC:N4:424
Luis-Eduardo Carson
Smoldyr LLC
2108 N ST # 10288
Sacramento, CA 95816
RE: The tariff classification of the “Curse of the Unholy Grail” game from China.
Dear Mr. Carson:
In your letter dated March 10, 2026, you requested a tariff classification ruling.
Photographs and a description of the “Curse of the Unholy Grail” game were submitted with your inquiry.
The “Curse of the Unholy Grail” is an adult drinking game comprised of 10 uniquely colored dice, 126
“Chaos” cards, 25 “Trial” cards, 4 “Unholy Grail” cards and game instructions. Gameplay is driven by
drawing cards to initiate actions or challenges and to ultimately locate the “Unholy Grail.” Certain cards
initiate 'trials' that are competitive, dice-driven challenges between players. Each player uses a die as their
game piece. Once all 4 “Unholy Grail” cards have been discovered, the game culminates in a final ‘trial’ that
determines the winner.
You propose classifying the “Curse of the Unholy Grail” under subheading 9504.90.9080 Harmonized Tariff
Schedule of the United States, (HTSUS), which provides for articles for arcade, table or parlor games,
including pinball machines...parts and accessories thereof: other: other...other. We disagree.
The “Curse of the Unholy Grail” consists of cards and dice put together for retail sale. The Explanatory
Notes to the HTSUS, GRI 3 (b) (VIII), state that the factor which determines essential character will vary
between different kinds of goods. It may, for example, be determined by the nature of the materials or
components, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use
of the goods. When the essential character of a set can be determined, the whole product is classified as if it
consisted only of the material or component that imparts the essential character to the good. In this instance,
the cards constitute the essential character of the game, as they primarily dictate gameplay actions.
The applicable subheading for the subject merchandise will be 9504.40.0000, HTSUS, which provides for
"Video game consoles and machines, articles for arcade, table or parlor games…parts and accessories
thereof: Playing Cards." 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