The tariff classification of a toy claw machine from China

N347572 April 23, 2025 CLA-2-95:OT:RR:NC:N4:424 CATEGORY: Classification TARIFF NO.: 9503.00.0073, 9903.01.24, 9903.01.63 Mr. John Coogan BJ's Wholesale Club, Inc. 350 Campus Drive Marlborough, MA 01752 RE: The tariff classification of a toy claw machine from China Dear Mr. Coogan: In your letter submitted on April 8, 2025, you requested a tariff classification ruling. Photographs and a description of the “Electronic Arcade Claw Crane Game,” item number 326669, were submitted with your inquiry. The article under consideration, BJ's Wholesale Club, item #326669, is a small scale, battery operated, plastic toy representation of a real claw machine, measuring approximately 10.79" x 8.58" x 12". The rectangular transparent container can be filled with small objects through a 7.8” x 6.89” door opening located in the back of the toy. The toy claw machine comes with 10 plastic capsules, to be filled with small prizes or candy, and 6 plastic tokens used to start the game and move the claw crane. The toy is designed to be user friendly by allowing a player unlimited attempts at lowering the crane claw within a 45 second time limit. The claw/grabber is manipulated with 3 levers situated on the front of the machine; one lever moves the claw forwards and backwards, the next lever moves it left to right and the third moves it up and down, in addition to opening the claw to grab prizes. If the player is successful at grabbing a prize and dropping it through the hatch, the item will come out through the square opening beneath, and to the left, of the levers. The machine is activated with the provided tokens and plays music when the claw is in use. The toy requires 6 x AA batteries which are not included with the product. Due to the construction, size, and limited function of the claw machine, it will be classified as a toy. The toy claw machine is principally designed for the amusement of children 6 years of age and older. In your request, you suggest classification of this product as a toy in subheading 9503.00.0073, Harmonized Tariff Schedule of the United States (HTSUS). We agree. The applicable subheading for the “Electronic Arcade Claw Crane Game,” item number 326669,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. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty.? At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition to subheading 9503.00.0073, HTSUS, listed above. Effective April 5, 2025, Executive Orders implemented ?Reciprocal Tariffs.?? All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs.? Products of China, including Hong Kong and Macau, will be assessed an additional ad valorem rate of duty of 125 percent.? Products from all other countries will be subject to an additional 10 percent ad valorem rate of duty.? At the time of entry, you must report the Chapter 99 heading applicable to your product classification, 9903.01.63, in addition to subheading 9503.00.0073, HTSUS, listed above. 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. 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