CLA-2-85:OT:RR:NC:N4 410
Jake Wolford
Wolfeez
53 W 825 S
Willard, UT 84340
RE: The tariff classification of a dog walking kit from China
Dear Mr. Wolford:
In your letter dated August 3, 2026, you requested a tariff classification ruling on a dog walking accessory kit
from China.
The merchandise is referred to as the Walkalong Dog Leash Accessory Set (“kit”) which you described as
follows:
The kit is a specialized accessory designed exclusively for use during dog walking. The kit consists of a
pouch with two lights and an aluminum alloy S-climbing hook attached. Two Type-C charging cables are
included in the pouch. All of the items are packed together ready for retail sale. The flashlight is pen-like
with a clip and the safety light is constructed of an oval plastic housing with a red translucent diffusor on one
side containing LED lamps inside. A clip is built into the plastic housing.
You explain that the Walkalong pouch is a utility attachment that secures directly to a dog leash via
integrated clips. It features a neoprene and nylon/spandex textile housing, a dedicated waste bag dispenser,
and a small storage compartment for specific pet safety items (such as a safety light or pen). The Walkalong
pouch lacks any built-in handle, strap, or standalone carrying mechanism. The product is never worn or
carried independently by the human owner; it relies entirely on being suspended from a leash, while the user
holds the leash handle.
You suggest that the kit should be classified as a set under subheading 4201.00.3000, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for saddlery and harness for any animal (including
traces, leads, knee pads, muzzles, saddle cloths, saddle bags, dog coats and the like), of any material: Dog
leashes, collars, muzzles, harnesses and similar dog equipment; or alternatively, under subheading
4202.92.3131, HTSUS, which provides for travel, sports and similar bags, with outer surface of textile
materials, other, of man-made fibers, other; pursuant to General Rules of Interpretation (GRI) 3(b).
We disagree.
Classification under the HTSUS is made in accordance with the General Rules of Interpretation (GRIs). The
Explanatory Notes, which constitute the official interpretation of the HTSUS at the international level, state
in Note X to GRI Rule 3(b) that the term “goods put up in sets for retail sale” means goods that: (a) consist of
at least two different articles which are, prima facie, classifiable in different headings; (b) consist of articles
put up 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.
In this instance, the four items in the kit are classifiable in different headings and are put up in a manner
suitable for sale directly to users without repacking. However, there is no evidence that these items are put up
together to meet a particular need or carry out a specific activity. The pouch (with the S-climbing hook) has a
defined purpose as a container for carrying or attaching numerous different items. The lights are to provide
illumination when used in darkness or low light conditions and are unrelated to, and independent of the
pouch and S climbing hook. Based on the available information, there is no particular need or any specific
activity which these items would function together to meet or carry out. As such, the items do not satisfy the
criteria of GRI 3(b) as goods put up in sets for retail sale and are classified individually.
Further, the Walkalong pouch is used to contain personal effects while walking an owner’s dog. It secures
directly to the dog’s leash and is constructed of man-made textile material, and it features a waste bag
dispenser and a small storage compartment. You suggest classification of the Walkalong pouch in heading
4201, HTSUS, which provides for “Saddlery and harness for any animal (including traces, leads, knee pads,
muzzles, saddle cloths, saddle bags, dog coats and the like), of any material.” However, the pouch itself is not
directly used to constrain the dog as would a leash. It is used to provide storage, protection, portability, and
organization to the owner’s belongings while walking the dog. It attaches to the leash simply for
convenience.
Accordingly, the applicable subheading for the Walkalong pouch will be 4202.92.9100, HTSUS, which
provides for “Trunks, suitcases, vanity cases, attache cases, briefcases, school satchels, spectacle cases,
binocular cases, camera cases, musical instrument cases, gun cases, holsters and similar containers;…Other:
With outer surface of sheeting of plastic or of textile materials, Other: Other: With outer surface of textile
materials: Of man-made fibers (except jewelry boxes of a kind normally sold at retail with their contents).”
The general rate of duty will be 17.6 percent ad valorem.
The applicable subheading for the S-climbing hook will be 7616.99.5190, HTSUS, which provides for
“Other articles of aluminum: Other: Other: Other: Other: Other.” The general rate of duty will be 2.5 percent
ad valorem.
The applicable subheading for the flashlight will be 8513.10.2000, HTSUS, which provides for “Portable
electric lamps designed to function by their own source of energy (for example, dry batteries, storage
batteries, magnetos)…: Lamps: Flashlights.” The general rate of duty will be 3.5 percent ad valorem.
The applicable subheading for the safety light will be 8513.10.4000, HTSUS, which provides for “Portable
electric lamps designed to function by their own source of energy (for example, dry batteries, storage
batteries, magnetos)…: Lamps: Other.” The general rate of duty will be 12.5 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 Michael Chen at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division