The tariff classification of assorted articles from China.

N353931 October 15, 2025 CLA-2-39:OT:RR:NC:N4:415 CATEGORY: Classification TARIFF NO.: 3924.90.5650; 3926.40.0090; 8214.20.9000; 9615.11.4000; 9903.01.24; 9903.01.25; 9903.88.15 Melissa Lehmann M.Z. Berger & Co., Inc. 353 Lexington Avenue New York, NY 10016 RE: The tariff classification of assorted articles from China. Dear Ms. Lehmann: In your letter dated September 18, 2025, you requested a tariff classification ruling. Images were provided in lieu of samples. The initial request consisted of five items. The “Fantasia Metal Compact Mirror,” item number DSG683, will be addressed in N354464. The remaining four items will be discussed below. The first product under consideration is described as the “Marie Compact Mirror with Oil Blotting Sheets,” item number CIG241. It consists of a plastic compact mirror and oil blotting sheets housed in a plastic travel case that features Marie from Disney’s “Aristocats.” We find that the plastic mirror imparts the essential character to this article, General Rule of Interpretation (GRI) 3(b) noted. The second product under consideration is described as the “Ariel Comb and Claw Clip Set,” item number DPG294. This set includes a comb and claw clip, both made of acrylic plastic, that are decorated with a Disney’s “The Little Mermaid” theme. As both the comb and clip merit equal consideration, this set will be classified by the clip as it would be last in tariff, GRI 6 and 3(c) noted. The third product under consideration is described as the “Beauty and the Beast Faux Nails,” item number DPG295. It consists of 24 acrylic plastic artificial nails. There are 12 different designs, all with printed graphics and six of those designs featuring plastic rhinestone accents. They all feature a Disney’s “Beauty and the Beast” theme. The fourth product under consideration is described as the “Spiderman 7pc Nail Care Gift Set,” item number SMG131. This set features a nail clipper, cuticle clipper, tweezers, nail file, and cuticle pusher each made of carbon steel, nail scissors made of stainless steel, and they are all housed within a polyurethane plastic faux leather case. The case features Marvel’s “Spiderman.” The applicable subheading for the “Marie Compact Mirror with Oil Blotting Sheets,” item number CIG241, will be 3924.90.5650, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[t]ableware, kitchenware, other household articles and hygienic or toilet articles, of plastics: [o]ther: [o]ther: [o]ther.” The column one, general rate of duty is 3.4 percent ad valorem. The applicable classification for the “Ariel Comb and Claw Clip Set,” item number DPG294, will be 9615.11.4000, HTSUS, which provides for “[c]ombs, hair-slides and the like; hairpins, curling pins, curling grips, hair curlers and the like, other than those of heading 8516, and parts thereof: [c]ombs, hair-slides and the like: [o]f hard rubber or plastics: [o]ther: [n]ot set with imitation pearls or imitation gemstones.” The column one, general rate of duty is 5.3 percent ad valorem. The applicable subheading for the “Beauty and the Beast Faux Nails,” item number DPG295, will be 3926.40.0090, HTSUS, which provides for “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [s]tatuettes and other ornamental articles: [o]ther.” The column one, general rate of duty is 5.3 percent ad valorem. The applicable subheading for the “Spiderman 7pc Nail Care Gift Set,” item number SMG131, will be 8214.20.9000, HTSUS, which provides for “[o]ther articles of cutlery (for example, hair clippers, butchers' or kitchen cleavers, chopping or mincing knives, paper knives); manicure or pedicure sets and instruments (including nail files); base metal parts thereof: [m]anicure or pedicure sets and instruments (including nail files), and parts thereof: [m]anicure and pedicure sets, and combinations thereof: [o]ther.” The column one, general rate of duty is 4.1 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 subheadings 3924.90.5650, 3926.40.0090, 8214.20.9000, and 9615.11.4000, 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 subheadings 3924.90.5650, 3926.40.0090, 8214.20.9000, and 9615.11.4000, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 3924.90.5650, 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 3924.90.5650, 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/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 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 CBP 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, please contact National Import Specialist Kristopher Burton at kristopher.burton@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division