The tariff classification of decorative iron garden sculptures from China

N353015 September 15, 2025 CLA-2-83:OT:RR:NC:N5:121 CATEGORY: Classification TARIFF NO.: 8306.29.0000; 9903.01.24; 9903.01.25 Ms. Regina Woody Hobby Lobby Stores 7707 SW 44th Street Oklahoma City, OK 73179 RE: The tariff classification of decorative iron garden sculptures from China Dear Ms. Woody: In your letter dated August 26, 2025, you requested a tariff classification ruling. The items under consideration are miniature decorative articles for mini fairy gardens or for potted plants. The first item under consideration is described as Metal Bird House, SKU# 1568161. It features a painted metal birdhouse hanging from a curled wire shepherd’s hook pick with embossed metal leaves and swirling vines. It measures approximately 8” in height and 2.75” in width. The second item is described as Butterfly Bench, SKU# 1176783. It is made of enameled metal wire with the back shaped to look like a butterfly. It measures approximately 2.625” in height, 1.875” in width, and 2.375” in depth. The third item is described as Garden Sign, SKU# 1397793. It features an oval shaped sign plate with metal wire scroll trim that hangs from a shepherd’s hook with a two-pronged stake. The plate contains the text “Garden”. It measures approximately 6” in height, 2.38” in width, and 0.13” in depth. All three decorative items are made of iron. You indicate that these decorative miniature items are used in mini fairy gardens and suggest that because the subject items are similar to dollhouse miniatures, they are classifiable in heading 9503, 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.” We disagree. Because the items are not dollhouse accessories, they are not classifiable as “parts and accessories” of articles of heading 9503. Further, pursuant to Note 3 to Chapter 95, HTSUS, “… parts and accessories which are suitable for use solely or principally with articles of this chapter are to be classified with those articles.” Since the subject items are not suitable for use solely or principally with articles of Chapter 95, HTSUS, they are not classifiable with such articles. The applicable subheading for the Metal Bird House, SKU# 1568161, the Butterfly Bench, SKU# 1176783, and the Garden Sign, SKU# 1397793 will be 8306.29.0000, HTSUS, which provides for Bells, gongs and the like, nonelectric, of base metal; statuettes and other ornaments, of base metal; photograph, picture or similar frames, of base metal; mirrors of base metal; and base metal parts thereof: Statuettes and other ornaments, and parts thereof: Other. 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 8306.29.0000, 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 8306.29.0000, HTSUS, listed above. 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 (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 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 Jennifer Jameson at jennifer.d.jameson@cbp.dhs.gov. Sincerely, (for) Denise Faingar Acting Director National Commodity Specialist Division