CLA-2-96:OT:RR:NC:N4:462
Kim Benedetto
Seasons USA Inc
2041 Genesee Street
Utica, NY 13501
RE: The tariff classification of accessories from China
Dear Ms. Benedetto:
In your letter dated July 13, 2026, you requested a tariff classification ruling.
A sample has been submitted and will be retained as requested.
The article under consideration is Item OEM27-0411, a Tea Cup Accessory Set. It includes a decorative
headband, a floral choker, and two floral cuffs. The horseshoe-shaped headband is made of plastic wrapped
in a polyester knit fabric and features an off-center teacup and saucer, both comprised of a printed polyester
knit fabric and felt. The choker contains a flower constructed from 100 percent polyester woven fabric,
attached to a 1-inch-wide by 15-inch-length textile ribbon secured with a hook and loop closure. The product
is worn around the neck. The cuffs each contain a flower constructed from 100 percent polyester woven
fabric, attached to a 3-inch-wide by 16-inch-length 100 percent polyester knit fabric. The polyester knit
fabric is attached to a narrow-elasticized band. The cuffs are worn around the wrist.
In your request, you propose classification under subheading 9505.60.9000, Harmonized Tariff Schedule of
the United States (HTSUS), which is an invalid tariff code. We believe you meant to propose subheading
9505.90.6000, HTSUS, as a costume. We disagree. The headband, choker, and cuffs, together or separately,
do not create an image of a specific character, creature, class of person, class of things or period of time. The
items are a collection of accessories, not classified in 9505.90.6000, HTSUS, as a costume. Further, the
items are not considered a set as they do not meet a particular need or carry out a specific activity. Therefore,
each item will be classified separately.
The decorative headband serves the utilitarian function of holding the wearer’s hair and would be considered
a hair-slide of heading 9615. As the fabric components that form the teacup and saucer imbue the headband
with its visual appeal, this office is of the opinion they would impart the essential character, General Rules of
Interpretation (GRI) 6 and 3(b) noted.
The cuffs are constructed from two different types of fabrics. Therefore, they are considered a composite
good, with classification determined by the material that imparts its essential character, GRI 3(b) noted. The
essential character of the cuffs is imparted by the 100 percent polyester knit fabric.
The applicable subheading for the decorative headband will be 9615.19.6000, HTSUS, which provides for
“Combs, hair-slides and the like; hairpins, curling pins, curling grips, hair curlers and the like, other than
those of heading 8516, and parts thereof: Combs, hair-slides and the like: Other: Other.” The column one,
general rate of duty is 11 percent ad valorem.
The applicable subheading for the choker will be 6217.10.9530, HTSUS, which provides for “Other made up
clothing accessories; parts of garments or of clothing accessories, other than those of heading 6212:
Accessories: Other: Other: Of man-made fibers.” The column one, general rate of duty is 14.6 percent ad
valorem.
The applicable subheading for the cuffs will be 6117.80.9540, HTSUS, which provides for “Other made up
clothing accessories, knitted or crocheted; knitted or crocheted parts of garments or of clothing accessories:
Other accessories: Other: Other: Of man-made fibers: Other.” The column one, general duty rate is 14.6
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 Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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 CBP Regulations (19 CFR 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 Sandra Walia at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division