The tariff classification of a children's wooden balance board from China

N352085 August 20, 2025 CLA-2-95:OT:RR:NC:N3:356 CATEGORY: Classification TARIFF NO.: 9506.91.0030; 9903.01.24; 9903.01.25; 9903.88.15 Ms. Renee Esquer Mattel, Inc. 333 Continental Blvd. El Segundo, CA RE: The tariff classification of a children's wooden balance board from China Dear Mr. Esquer: In your letter dated August 6, 2005, you requested a tariff classification ruling. Photographs and a description of the “Rockin’ Balance Board” were received with your inquiry. The product under consideration is a wooden balance board identified as the “Rockin’ Balance Board,” Mattel item # JHC04, measuring approximately 31.69” (L) x 11.61” (W) x 6.89” (H). The exercise device is a rectangular shape that bows in the middle and can support a weight of up to 153 lbs. The item can promote a child’s gross motor skills, balance, coordination, and strength by rocking side to side with feet resting on the board. A child’s feet can be positioned close together at the center of the board for easier balance, or further apart and closer to the edges for a more challenging experience. Children can test their skills, balance and coordination with exercise suggestions found on a “Tip” card provided in the retail packaging. The “Rockin’ Balance Board” is designed for children ages 3 years and older. You suggest classification of the “Rockin’ Balance Board” in subheading 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.” We disagree. We find that the merchandise at issue is of the same class or kind of articles and equipment for general physical exercise which are properly classified in heading 9506. The applicable subheading for the “Rockin’ Balance Board,” Mattel item # JHC04, will be 9506.91.0030, HTSUS, which provides for "Articles and equipment for general physical exercise, gymnastics, athletics, other sports…or outdoor games…; parts and accessories thereof: Other: Articles and equipment for general physical exercise, gymnastics or athletics; parts and accessories thereof...Other.” The rate of duty will be 4.6% 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 9506.91.0030, 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. At this time, products of China, Hong Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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 9506.91.0030, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9506.91.0030, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 9506.91.0030, 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. 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/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, contact National Import Specialist Maryalice Nowak at maryalice.nowak@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division