The tariff classification of baoding balls from China

N351885 August 5, 2025 CLA-2-73:OT:RR:NC:N1:164 CATEGORY: Classification TARIFF NO.: 7326.90.8688; 9903.01.24; 9903.81.90; 9903.01.25; 9903.88.03 James Lin Thinkbug LLC 4045 Five Forks Trickum Rd. SW Suite B9 #278 Lilburn, GA 30047 RE: The tariff classification of baoding balls from China Dear Mr. Lin: In your letter dated July 25, 2025, you requested a tariff classification ruling regarding baoding balls from China. Product information was submitted with your request. The items under consideration are described as solid stainless steel boading balls intended for hand therapy and stress relief. During use, an individual holds two baoding balls and rotates them in a circular motion. You claim that the repetitive, rhythmic movement and weight of the balls improves hand strength, dexterity, and blood circulation in the hand and wrist. At importation, the balls are packaged with a zippered felt bag in a colored cardboard box, ready for retail sale. Each baoding ball is 1.5 inches in diameter. Each pair weighs approximately one pound. You propose classification in subheading 9019.10.2010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Mechano-therapy appliances; massage apparatus; …parts and accessories thereof: Mechano-therapy appliances; massage apparatus; …parts and accessories thereof: Mechano-therapy appliances and massage apparatus; parts and accessories thereof: Mechano-therapy appliances. We disagree. Classification under the HTSUS is in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods will be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 will then be applied in order. The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official interpretation of the HTSUS. While not legally binding nor dispositive, the ENs provide a commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of these headings. See T.D. 89-80, 54 Fed. Reg. 35127 (August 23, 1989). Of relevance, the ENs to heading 9019, HTSUS, specify that the heading covers appliances which operate by mechanical reproduction of various movements to treat disease of the joints or muscles. Such treatment is usually carried out under medical supervision. Based on the submitted information, the boading balls are solid stainless steel spheres and are neither appliances nor mechanical in nature. Further, they differ in purpose and use from the mechano-therapy appliances classified under heading 9019. Consequently, they are not classified in heading 9019, HTSUS. Heading 7326, HTSUS, is a residual or basket provision which covers a wide range of iron or steel articles that are not more specifically provided for elsewhere in the HTSUS. The ENs to heading 7326 state that “This heading covers all iron or steel articles obtained by forging or punching, by cutting or stamping or by other processes such as folding, assembling, welding, turning, milling or perforating other than articles included in the preceding headings of this Chapter or covered by Note 1 to Section XV or included in Chapter 82 or 83 or more specifically covered elsewhere in the Nomenclature.” An article of iron or steel can be classified in heading 7326 if it is determined that the item is not more specifically provided for in any other heading of the tariff. Noting the solid stainless steel baoding balls are not more specifically provided for in heading 9019, or any other heading of the tariff, the baoding balls can be classified in heading 7326, HTSUS. The applicable subheading for the solid stainless steel baoding balls will be 7326.90.8688, HTSUS, which provides for Other articles of iron or steel: Other: Other: Other: Other. The general rate of duty will be 2.9 percent ad valorem. 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 7326.90.8688, HTSUS, listed above. On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter 99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 percent upon the value of the steel content. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.81.90, in addition to subheading 7326.90.8688, HTSUS. Derivative iron or steel products processed in another country from steel articles melted and poured in the United States, provided for in heading 9903.81.92, are not subject to the additional ad valorem duties. 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. At this time products from all countries will be subject to an additional 10 percent ad valorem rate of duty. For products covered by heading 9903.81.90, this additional duty applies to the non-steel content of the merchandise. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading 7326.90.8688, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 7326.90.8688, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 7326.90.8688, HTSUS, listed above. The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively. The tariffs and additional 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/. 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 (C.F.R.), 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 C.F.R. 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 Paul Taylor at paul.m.taylor@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division