The tariff classification of the “Bolt” from China

N295757 April 20, 2018 CLA-2-95:OT:RR:NC:N4:424 CATEGORY: Classification TARIFF NO.: 9503.00.0073 Ms. Sara Sampson Sphero, Inc. 4772 Walnut St., Suite 206 Boulder, CO 80301 RE: The tariff classification of the “Bolt” from China Dear Ms. Sampson: In your letter received April 4, 2018, you requested a tariff classification ruling. Photographs and a description of the Sphero “Bolt” were submitted with your inquiry. The item is an app-enabled robotic ball that is both a toy and a learning tool. Included in the packaging together with the robotic toy are a USB to micro USB charging cable, an inductive charging cradle and an envelope with a quick start guide. All of these components are housed in a pulp tray to protect the contents during shipping. The robot has one rechargeable lithium polymer battery to power 2 motors, 2 LED lights, an LED matrix that mixes red, green and blue light, and various sensors. The sensors include a magnetometer to determine direction, an inertial measuring unit to stabilize the robot, motor encoders that can measure rolling speed and distance, and an ambient light sensor to measure light intensity. There are two processors in the robot that handle the functionality of all of the sensors as well as the Bluetooth connection to a smartphone. All of these components are housed in the robot’s polycarbonate body that measures approximately 73mm in diameter and weighs 192g. You suggested that the “Bolt” be classified under 9503.00.0073 as a toy principally designed for the amusement of children between 3 and 12 years of age, as it greatly resembles the “SPRK+”, a similar product that received the same classification in a prior ruling request. The applicable subheading for the Sphero “Bolt” will be 9503.00.0073, Harmonized Tariff Schedule of the United States (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. 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, contact National Import Specialist Roseanne Murphy at roseanne.j.murphy@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division