NY N341163: The tariff classification of the “Easy Store Building Bricks Table” from China

Native CBP ruling rendition. Applicability is fact-specific; modification/revocation relationships and original publisher date are retained. Publisher sentinel year0001 means unknown date, not a historical legal adoption.

N341163 

July 16, 2024 

CLA-2-95:OT:RR:NC:N4:424

CATEGORY: Classification

TARIFF NO.: 9503.00.0073

Mr. Patrick B. Klein
Neville Peterson, LLP
One Exchange Plaza
55 Broadway, Suite 2602
New York, NY 10006

RE:      The tariff classification of the “Easy Store Building Bricks Table” from China

Dear Mr. Klein:

In your letter submitted on July 9, 2024, you requested a tariff classification ruling on behalf of your client, Delta Enterprise Corp.

Photographs and a description of the “Easy Store Building Bricks Table,” were submitted with your inquiry. 

The article under consideration is a low rise, rectangular wooden, table measuring 32.6" x 17.8" x 11.4" with a plastic permanent "brick board" play surface, 2 underside storage bins, and 75 plastic "play bricks."  The “brick board” base provides the play environment where children snap the "play bricks" onto the board’s surface and build imaginative structures.  The molded plastic bricks snap together by means of round protrusions on the bricks and the board, giving children a manipulative play experience.  The product features a carry handle and folding legs that raise the board off the floor by less than a foot allowing enough space for children to sit on the floor while playing with the toy.  The “Easy Store Building Bricks Table” is principally designed for the amusement of children ages 3 years and older.

You suggest classification of the “Easy Store Building Bricks Table” as a toy under 9503.00.0073, Harmonized Tariff Schedule of the United States (HTSUS).  We agree.

The applicable subheading for the “Easy Store Building Bricks Table” will be 9503.00.0073, (HTSUS), which provides for “Tricycles, scooters, pedal cars, and similar wheeled toys…dolls, other toys…puzzles of all kinds; parts and accessories thereof… ‘Children’s products’ as defined in 15 U.S.C. § 2052: Other: Labeled or determined by importer as intended for use by persons: 3 to 12 years of age.”  The rate of duty will be Free. 

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 on World Wide Web at https://hts.usitc.gov/current.
Importations of this product may be subject to the provisions of Section 133 of the Customs Regulations if they copy or simulate a registered trademark, trade name or copyright recorded with U.S. Customs and Border Protection.  If you are an authorized importer of the product we recommend notifying your local Customs office prior to importation.

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 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 Roseanne Murphy at roseanne.j.murphy@cbp.dhs.gov.

Sincerely, 

Steven A. Mack 
Director 
National Commodity Specialist Division