The tariff classification of math manipulatives from China

N355872 November 26, 2025 CLA-2-49:OT:RR:NC:5:130 CATEGORY: Classification TARIFF NO.: 4911.90.8000; 3926.90.9989; 4421.99.9880; 9903.01.24; 9903.01.22; 9903.01.25; 9903.01.31 Mr. Henry Borenson Borenson & Associates, Inc. 2949 Diamond Ave. Allentown, PA 18103 RE: The tariff classification of math manipulatives from China Dear Mr. Borenson: In your letter, dated October 22, 2025, you requested a tariff classification ruling on math manipulatives. The request was returned to you for additional information, which was received by this office on November 7, 2025. Product information, photos, and samples were submitted for our review. In your letters, you have identified four math manipulatives that will be imported. The first item under consideration is printed blocks. The blocks are wooden, are painted red and green, and are printed on 6 sides with numbers, like dice. They measure 2cm x 2cm x 2cm and your submission indicates that 40,000 sets of 8 blocks will be imported. You indicate that you will also import 1,050 sets of the same cubes in a 2.5cm x 2.5cm x 2.5cm size. The second item under consideration is described as plastic pawns. They will measure 5/8” wide by 7/8” tall. Your submission indicates that 30,000 packets of plastic pawns will be imported with each packet containing eight blue and eight white pawns. The third item under consideration is described as plastic fraction tiles. Your submission indicates that 16,000 sets will be imported with each set containing three yellow tiles representing one whole, six red tiles each representing one-half, nine blue tiles each representing a third, and 15 green tiles each representing one-sixth. The fourth item under consideration will be large wooden pawns. They measure 2cm wide by 4.5cm tall and are painted white and blue. Your submission indicates that you will be importing 8000 of the white pawns and 8000 of the blue pawns. You suggest that the items are classifiable in subheading 9023.00.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Instruments, apparatus and models, designed for demonstrational purposes (for example, in education or exhibitions), unsuitable for other uses, and parts and accessories thereof. We disagree. The items are not merely demonstrational and could be used in several different applications. Classification under the 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. The four items, while usually used together, are not put up in sets for retail sale. Nor are they imported in equal numbers. Therefore, the items will be classified separately. The most significant element of the blocks is the printed numbers. Therefore, they will be classified as printed matter. The applicable subheading of the polyester printed blocks 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. As the pawn packets and fraction tile sets would be considered articles of plastic, and as they are not more specifically provided for elsewhere, the applicable subheading will be 3926.90.9989, HTSUS, which provides for Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Other: Other. The general rate of duty is 5.3 percent ad valorem. The applicable subheading for the large blue and white wood pawns will be 4421.99.9880, HTSUS, which provides for Other articles of wood: Other: Other: Other: Other: Other. The general rate of duty will be 3.3 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 subheading 9903.01.24, HTSUS, other than products classifiable under subheadings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 subheading, i.e. 9903.01.24, in addition to subheadings 3926.90.9989 and 4421.99.9880, HTSUS, listed above. The printed blocks are considered to be “informational materials” and are excluded from these duties. At the time of entry, you must report the applicable Chapter 99 subheading, 9903.01.22, in addition to subheading 4911.99.8000, HTSUS. 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 subheading applicable to your product classification, i.e., 9903.01.25, in addition to subheadings 3926.90.9989 and 4421.99.9880, HTSUS, listed above. As noted, the printed blocks are considered informational materials and are exempt from these duties. At the time of entry, you must report the applicable subheading, 9903.01.31, in addition to subheading 4911.99.8000, HTSUS. 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 can be found 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) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division