CLA-2-84:OT:RR:NC:N1:104
Mark Baxa
FerniaCreek Global Supply Chain Consulting Company
2208 Missouri Blvd, Suite 102
Jefferson City, MO 65109
RE: The tariff classification of a cordless power hand-held spreader kit from China
Dear Mr. Baxa:
In your letter dated March 10, 2026, on behalf of your client, Chervon Industries, you requested a tariff
classification ruling.
The product in question is a portable, electric hand-held power spreader kit used to spread seed, fertilizer, and
pesticides for outdoor gardening, horticultural, and lawn-care applications. As imported, the product will be
packaged for retail sale as a set or kit, the contents of which include the electro-mechanical spreader, a
removeable 24V 2Ah lithium-ion (Li) battery pack, battery charger, and printed user manuals. The spreader
has an internal electric motor that drives a rotating impeller (spreader wheel) to distribute granular materials
in a uniform broadcast pattern. The spreader also features an ergonomic handle, a 1.2-gallon hopper for
holding the granular material, a flow-rate knob, speed-control dial, edge-control deflector, baffle and agitator,
and a printed circuit board assembly to manage motor speed and operation.
We understand that no components will be added to the kit subsequent to importation. Accordingly, we
consider General Rule of Interpretation (GRI) 3(b), Harmonized Tariff Schedule of the United States
(HTSUS). Explanatory Note X to GRI 3(b) provides that for the purpose 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 up together to meet a
specific activity; and (c) are put up in a manner suitable for sale directly to users without repackaging. GRI 1,
HTSUS, states in part that for legal purposes, classification shall be determined according to the terms of the
headings and any relative section or chapter notes.
Goods that are, prima facie, classifiable under two or more headings, are classifiable in accordance with GRI
3, HTSUS. GRI 3(a) states in part that when two or more headings each refer to part only of the items in a set
put up for retail sale, those headings are to be regarded as equally specific, even if one heading gives a more
precise description of the good. The hand-held spreader kit consists of at least two different articles that are,
prima facie, classifiable in different subheadings. The kit consists of articles put up together to carry out a
specific activity, i.e., granular material spreading for lawns, gardens and raised beds in residential and
commercial settings. Finally, the articles are put up in a manner suitable for sale directly to users without
repacking. Therefore, the kit in question is within the term “goods put up in sets for retail sale.” GRI 3(b)
states in part that goods put up in sets for retail sale, which cannot be classified by reference to 3(a), are to be
classified as if they consisted of the component which gives them their essential character. The primary
purpose of the kit is to spread seed, fertilizer, and other granular materials. This is done through the
battery-powered spreader. The spreader plainly provides the essential character to the set.
In accordance with GRI 3(b), the applicable subheading for the hand-held power spreader kit will be
8479.89.6500, HTSUS, which provides for machines and mechanical appliances having individual functions
not specified or included elsewhere (in chapter 84): other machines and mechanical appliances: other:
electromechanical appliances with self-contained electric motor: other. The general rate of duty will be 2.8
percent ad valorem.
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 Arthur Purcell at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division