The tariff classification of wall clock from China

N353561 September 23, 2025 CLA-2-91:OT:RR:NC:N3:348 CATEGORY: Classification TARIFF NO.: 9105.21.8050; 9903.01.24; 9903.01.25 Geary Priehs Santoki LLC 1100 N Opdyke Rd, Suite 200 Auburn Hills, MI 48326 RE: The tariff classification of wall clock from China Dear Mr. Priehs: In your letter dated September 10, 2025, you requested a tariff classification ruling. A sample was received and will be returned to you as requested. The submitted sample, LEGO My Own Creation Wall Clock, Item # 53771, is constructed from Acrylonitrile Butadiene Styrene plastic. The LEGO My Own Creation Wall Clock measures approximately 9.25 inches in height, 9.25 inches in length and 1.75 inches in width. Item # 53771 is an analog wall clock with a quartz battery powered movement. There are no jewels in the movement. The clock is housed in a plastic case and has a square dial with an hour, minute and second hands. On the back of the plastic housing is an opening for changing the battery. The wall clock requires one AA batteries to operate. The battery is included. The face of the clock contains a LEGO building plate for the purpose of designing and redesigning the face with LEGO bricks and minifigures. You request classification under subheading 9503.00.0090, Harmonized Tariff Schedule of the United States, which provides for “Tricycles, scooters, pedal cars and similar wheeled toys… dolls, other toys… puzzles of all kinds; parts and accessories thereof… Other.” We disagree with your proposed classification. We find that the merchandise concerned is not a toy principally designed for amusement, but rather a fully functional utilitarian wall clock. For tariff purposes, this product is not considered to be a toy principally designed for amusement and is therefore precluded from classification in Heading 9503. The applicable subheading for the Item # 53771 will be 9105.21.8050, HTSUS, which provides for other clocks; wall clocks; electrically operated; other. The rate of duty will be 30 cents each plus 6.9 percent ad valorem on the case plus 5.3 percent ad valorem on the battery. 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 9105.21.8050, 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 9105.21.8050, 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 Rosemarie Hayward at rosemariecasey.hayward@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division