The tariff classification of books with cards or tiles from China

N353632 October 2, 2025 CLA-2-49:OT:RR:NC:5:130 CATEGORY: Classification TARIFF NO.: 4901.99.0093; 4911.99.6000; 4911.99.8000; 9504.40.0000; 9903.01.24; 9903.01.22; 9903.01.25; 9903.01.31; 9903.88.15 Ms. Sonia Serrato Canchola Half Price Books, Records, Magazines 2700 Lone Star Drive Dallas, TX 75212 RE: The tariff classification of books with cards or tiles from China Dear Ms. Serrato Canchola: In your letter, dated September 11, 2025, you requested a binding tariff classification ruling on several sets of books with cards or tiles. Product information and samples were submitted for our review. The first item under consideration is Item 2502004, “Essential Guitar Chords Book and Card Deck”. The kit consists of a 128-page book designed to instruct the user on how to play guitar chords, and a deck of 64 paper flash cards. The flash cards are lithographically printed. The book and cards are packaged together in a box for retail sale. The second item is Item 2202089, “Moon Magic Book and Card Deck”. There is a 50-card deck of lithographically-printed, paper divination cards and a 128-page book explaining how to read the cards. The book and cards are packaged together in a box for retail sale. The third item is Item 2405039, “Runes Book and Tile Set”. There is a set of 25 silkscreened, plastic rune tiles and a 128-page book explaining how to read the rune tiles for divination. The tiles and the book are packaged together in a box for retail sale. The fourth item is Item 2409133 “Astrology Oracle Book and Card Deck”. The kit includes a 50-card deck of lithographically-printed, paper astrology cards and a 128-page book instructing on how to read the cards for divination. The book and the cards are packaged together in a box for retail sale. The last item is Item 2502058, “Classic Rider Waite Smith Tarot”. The kit consists of a 78-card tarot deck and a 48-page book explaining how to read the tarot cards. The tarot cards and the book are packaged together in a box for retail sale. Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is made in accordance with the General Rules of Interpretation (GRIs). The Explanatory Notes, which constitute the official interpretation of the HTSUS at the international level, state in Note (X) to GRI Rule 3 (b) that the term "goods put up in sets for retail sale" means goods that: (a) consist of at least two different articles which are, prima facie, classifiable in different headings; (b) consist of articles put up together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without repacking. Goods classifiable under GRI 3(b) are classified as if they consisted of the material or component which gives them their essential character, which may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the article. All of the kits meet the definition of “goods put up in sets for retail sale”. They each consist of at least two items classifiable in different headings, they are each packaged together for retail sale, and they all are put up together to carry out a specific activity. The Essential Guitar Chords Book and Card deck both work together to teach a person how to play guitar. The book is essential for teaching guitar, and the flash cards support learning. Therefore, the essential character of the Guitar Chords set is the book. The Moon Magic Book and Card Deck teach the user how to read the moon cards for divination. The moon cards are the critical component, and the book teaches the user how to read the cards. Therefore, the essential character of the Moon Magic set is the moon cards. The Runes Book and Tile Set teaches the user how to read rune tiles for divination. The rune tiles are the critical component, and the book teaches the used how to read the tiles. Therefore, the essential character of the runes set is the runes tiles. The most important component of the runes tiles is the printed runes. The Astrology Oracle Book and Card Deck teach the user how to read astrology cards for divination. The astrology cards are the critical component, and the book teaches the user how to read the cards. Therefore, the essential character of the Astrology Oracle set is the astrology cards. Finally, the Tarot Deck set teaches the user how to read the tarot cards for divination. The critical component of the tarot set is the tarot cards. We note that the first four sets are not games, and that tarot is historically regarded as a game. The applicable subheading for Item 2502004, “Essential Guitar Chords Book and Card Deck” will be 4901.99.0093, HTSUS, which provides for Printed books, brochures, leaflets and similar printed matter, whether or not in single sheets: Other: Other: Other: Other: Other: Containing 49 or more pages each (excluding covers). The general rate of duty will be free. The applicable subheading for Item 2202089, “Moon Magic Book and Card Deck” will be 4911.99.6000, HTSUS, which provides for Other printed matter, including printed pictures and photographs: Other: Other: Other: Printed on paper in whole or in part by a lithographic process. The general rate of duty will be free. The applicable subheading for Item 2405039, “Runes Book and Tile Set” will be 4911.99.8000, HTSUS, which provides for Other printed matter, including printed pictures and photographs: Other: Other: Other: Other. The general rate of duty will be free. The applicable subheading for Item 2409133 “Astrology Oracle Book and Card Deck” will be 4911.99.6000, HTSUS, which provides for Other printed matter, including printed pictures and photographs: Other: Other: Other: Printed on paper in whole or in part by a lithographic process. The general rate of duty will be free. The applicable subheading for Item 2502058, “Classic Rider Waite Smith Tarot” will be 9504.40.0000, HTSUS, which provides for Video game consoles and machines, table and parlor games…: Playing cards. The general 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 time of entry, you must report the applicable Chapter 99 subheading, 9903.01.24, HTSUS, in addition to 9504.40.0000, HTSUS. Merchandise classifiable under subheadings 4901.99.0093, 4911.99.6000, and 4911.99.8000, HTSUS, constitutes “any information or informational materials” encompassed by 50 U.S.C. § 1702(b)(3). Accordingly, such merchandise is exempt from additional duties under Executive Order 14195 pursuant to subheading 9903.01.22, HTSUS. At the time of entry, you must report the applicable Chapter 99 subheading, 9903.01.22, in addition to subheadings 4901.99.0093, 4911.99.6000, and 4911.99.8000, 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 from China, Hong Kong, and Macau will be subject to an additional 10 percent ad valorem rate of duty. At time of entry, you must report the applicable Chapter 99 subheading, 9903.01.25, HTSUS, in addition to 9504.40.0000, HTSUS. As noted, subheadings 4901.99.0093, 4911.99.6000, and 4911.99.8000, HTSUS, fall within an excepted subheading, as they constitute “informational materials”. At the time of entry, you must report the Chapter 99 subheading applicable to your product classification, 9903.01.31, in addition to subheadings 4901.99.0093, 4911.99.6000, and 4911.99.8000, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 4901.99.0093, 4911.99.6000, and 4911.99.8000, 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, 9903.88.15, in addition to subheadings 4901.99.0093, 4911.99.6000, and 4911.99.8000, 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, 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/remedies/301-certain-products-china, 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 on the World Wide Web 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 Regulations (19 CFR 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 Laurel Duvall at laurel.duvall@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division