The tariff classification of a plastic bookmark kit from China

N353980 October 15, 2025 CLA-2-39:OT:RR:NC:N4:422 CATEGORY: Classification TARIFF NO.: 3926.10.0000; 9903.01.24; 9903.01.25 Ms. Krista Fedon OOLY, LLC. 5607 Palmer Way Carlsbad, CA 92010 RE: The tariff classification of a plastic bookmark kit from China Dear Ms. Fedon: In your letter dated September 19, 2025, you requested a tariff classification ruling. Photographs and an instructional guide were submitted along with your request. The item is referred to as the SKU 161-154 Gem Bookmark Kit. The product is a craft kit designed to decorate plastic bookmarks. The kit includes 1 instructions sheet, 8 plastic bookmark pieces, 5 packs of multi-colored plastic gem pieces, 1 plastic tray, 1 stylus, and multi-colored butcher’s twine. All of the items will be packaged together for retail sale. The plastic bookmark kit is intended for ages 6 years and up. The 8 plastic bookmarks are comprised of two layers of polypropylene (PP) plastic sheeting material. The top layer measures approximately 0.18 millimeters thick and the bottom layer is approximately 0.45 millimeters thick. The bookmarks are available in two sizes: The square shaped bookmark measures approximately 4.00 inches long by 0.02 inches wide by 4.00 inches high. The rectangular shaped bookmark measures approximately 6.00 inches long by 0.02 inches wide by 2.00 inches high. The Explanatory Notes to the Harmonized Tariff System provide guidance in the interpretation of the Harmonized Commodity Description and Coding System at the international level. Explanatory Note X to GRI 3(b) provides 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. This office considers the gem bookmark kit to be a set for tariff classification purposes, with the essential character imparted by the polypropylene plastic bookmarks. The applicable subheading for the SKU 161-154 Gem Bookmark Kit will be 3926.10.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other articles of plastics and articles of other materials of headings 3901 to 3914: Office or school supplies.” The general rate of duty will be 5.3 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 subheading 3926.10.0000, 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 3926.10.0000, 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 Dana L. Giammanco at dana.l.giammanco@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division