USMCA Eligibility of Plastic Dolls; Regional Value Content

H357256 June 22, 2026 OT:RR:CTF:VS H357256 RRB CATEGORY: Origin Daniel Chang Mexico Yutotech Packaging Company, S. de R.L. de C.V. MYP240308PD1 Chapala, No. 303 Guadalajara 45860 Mexico RE: USMCA Eligibility of Plastic Dolls; Regional Value Content Dear Mr. Chang: This is in response to your ruling request, dated January 22, 2026, regarding preferential tariff treatment under the United States-Mexico-Canada Agreement (“USMCA”) for plastic dolls. In New York Ruling Letter (“NY”) N356375, dated December 17, 2025, U.S. Customs and Border Protection’s (“CBP”) National Commodity Specialist Division (“NCSD”) issued a ruling with respect to the country of origin and tariff classification of the subject plastic dolls. With respect to eligibility of the plastic dols for preferential tariff treatment under the USMCA, CBP determined that the applicable rule of origin consists of regional value content (“RVC”) requirements. Accordingly, you were advised to forward your request to our office. Our ruling with respect to eligibility under the USMCA is set forth below. FACTS: The product at issue is the Pop Mart Mega Space Molly 400% Optimus Prime doll. It is a plastic doll that measures approximately 12 inches in height and features a moveable head, mask, and arms. It is designed principally for the amusement of persons aged 15 years and older. You explain that all parts of the plastic doll, including the head, arms, torso, legs, mask, oxygen cylinder, tubes, and gun, are injection-molded of acrylonitrile butadiene styrene (“ABS”) plastic in China and exported to Mexico. In Mexico, the components 2 are assembled via screwing and gluing. The finished doll is packaged for retail sale and exported directly to the United States We note that in NY N356375, CBP determined that the country of origin for duty purposes of the subject plastic doll is China. CBP also determined that the plastic doll is classified in subheading 9503.00.0090, Harmonized Tariff Schedule of the United States Annotated (“HTSUSA”), which provides for “Tricycles, scooters, pedal cars, and similar wheeled toys… dolls, other toys… parts and accessories thereof… Other.” For purposes of USMCA eligibility, CBP noted that the nonoriginating components of the plastic dolls did not satisfy the applicable tariff shift rule for merchandise classified in subheading 9503.00, HTSUS. In support of your request for determination of USMCA eligibility under the applicable regional value content requirements for plastic dolls, you submitted a costed bill of materials and spreadsheets that detail production costs for calculating RVC. On May 7, 2026, in further support of your ruling request, you provided a detailed origin qualification analysis with revised and updated information, including a revised costed bill of materials, which was prepared for you by an outside accounting firm. As part of the supplemental origin qualification analysis, you explain that the value of originating materials (VOM) includes labor and manufacturing costs. According to the revised costed bill of materials, all but two of the components are of Chinese origin. For example, the Chinese-origin “ABS colored head assembly 151 x 126.8 x 120 mm” has a unit cost of $4.7479; the Chinese-origin “ABS colored front component 103 x 112 x 74 mm” has a unit cost of $4.7479; and the Chinese-origin “ABS colored lower body assembly 109 x 102 x 88.6 mm” has a unit cost of $4.1549. The revised costed bill of materials identifies the two Mexican-origin components as “POP MART MEGA SPACE MOLLY 400% Optimus Prime Color Paper box” with a unit cost of $0.7099, and “W9 (E-Flute) 130/130 FSC MIX 675 x 860 mm” with a unit cost of $0.2366. Our determination below takes into account all of the aforementioned documentation. ISSUE: Whether the plastic dolls are eligible for preferential tariff treatment under the USMCA when imported from Mexico into the United States. LAW AND ANALYSIS: The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note (“GN”) 11 of the HTSUS implements the USMCA. 3 GN 11(a)(i) provides: Goods that originate in the territory of Mexico, Canada or the United States (hereinafter referred to as “USMCA country” or “USMCA countries” as further defined in subdivision (l)(xxiv) of this note) under the terms of subdivision (b) of this note and regulations issued by the Secretary of the Treasury (including Uniform Regulations provided for in the USMCA), and goods enumerated in subdivision (p) of this note, when such goods are imported into the customs territory of the United States and are entered under a subheading for which a rate of duty appears in the “Special” subcolumn, followed by the symbol “S” in parentheses, are eligible for such duty rate, in accordance with section 202 of the United States-Mexico-Canada Agreement Implementation Act; and . . . GN 11(b) sets forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11(b) states: For the purposes of this note, a good imported into the customs territory of the United States from the territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the tariff schedule as a “good originating in the territory of a USMCA country” only if— (i) the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries; (ii) the good is a good produced entirely in the territory of one or more USMCA countries, exclusively from originating materials; (iii) the good is a good produced entirely in the territory of one or more USMCA countries using nonoriginating materials, if the good satisfies all applicable requirements set forth in this note (including the provisions of subdivision (o)); or … Since the plastic dolls contain nonoriginating materials, they are not considered good wholly obtained or produced entirely in a USMCA country under GN 11(b)(i), nor are they goods produced exclusively from nonoriginating materials per GN 11(b)(ii). Thus, we must determine whether the plastic dolls qualify under GN 11(b)(iii). To qualify for preferential tariff treatment under GN 11(b)(iii), a good must meet a product specific rule of origin, which often includes an RVC. As we stated in NY N356375, the plastic dolls are classified in subheading 9503.00.00, HTSUS. 4 The applicable rule of origin for goods classified under subheading 9503.00.00, HTSUS, is set forth at GN 11(o)/95.1, which provides, in relevant part: 1. (A) A change to subheading 9503.00 through 9505.90 from any other subheading, including another subheading within that group; or (B) No change in tariff classification to a good of any of subheadings 9503.00 through 9505.90, provided there is a regional value content of not less than: (1) 45 percent where the transaction value method is used; or (2) 35 percent where the net cost method is used. In NY N356375, we confirmed that GN 11(o)/95.1(A) is inapplicable because each of the components of the plastic doll is classified in subheading 9503.00, HTSUS, and therefore, does not meet the tariff shift set out in the relevant rule. Accordingly, we apply GN 11(o)/95.1(B), which provides for a regional value content requirement of not less than 45 percent using the transaction value method or not less than 35 percent using the net cost method. You have provided us with information pertaining to the cost of the materials, and you utilized the transaction value in your calculations to calculate the RVC of the originating materials. Under GN 11(c)(ii), the transaction value method is set forth as follows: Transaction value method: An importer, exporter, or producer of a good may calculate the regional value content of a good on the basis of the following transaction value method: RVC = ((TV - VNM)/TV) x 100 where RVC means the regional value content of the good, expressed as a percentage; TV means the transaction value of the good adjusted to exclude any costs incurred in the international shipment of the good; and VNM means the value of nonoriginating materials, including materials of undetermined origin, used by the producer in the production of the good. For the overall transaction value, you have provided a quotation list, which identifies the Free On Board (FOB) price of the subject doll as $91.94. According to the costed bill of materials that was included with your May 7, 2026, origin qualification analysis, the total value of the nonoriginating materials (excluding packaging material 5 for retail sale, assembling charges and domestic land freight within Mexico) is $42.86.1 Based on these figures, the RVC is ($91.94 - $42.86)/$91.94) x 100 = 53.38%. This is above the 45% minimum required by GN 11(o)/ 95.1(B)(1). Accordingly, the plastic doll classified under subheading 9503.00.00, HTSUS, qualifies as a USMCA originating good. Provided that all other requirements are met, the plastic doll will be eligible for preferential tariff treatment under the USCMA when imported into the United States from Mexico. HOLDING: Based on the information provided, the plastic doll is eligible for preferential tariff treatment under the USMCA. Please note that 19 C.F.R. § 177.9(b)(1) provides that “[e]ach ruling letter is issued on the assumption that all of the information furnished in connection with the ruling request and incorporated in the ruling letter, either directly, by reference, or by implication, is accurate and complete in every material respect. The application of a ruling letter by [CBP] field office to the transaction to which it is purported to relate is subject to the verification of the facts incorporated in the ruling letter, a comparison of the transaction described therein to the actual transaction, and the satisfaction of any conditions on which the ruling was based.” A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is entered. If the documents have been filed without a copy, this ruling should be brought to the attention of the CBP officer handling the transaction. Sincerely, Monika R. Brenner, Chief Valuation and Special Programs Branch 1 We note that in your initial submission, you provided the VNM based on the Cost, Insurance, and Freight (CIF) value of each nonoriginating material. You corrected this in your May 7, 2026, submission to include the VNM based on the FOB price of each nonoriginating material.