The tariff classification of children’s soft books from China

N355963 December 3, 2025 CLA-2-49:OT:RR:NC:5:130 CATEGORY: Classification TARIFF NO.: 4903.00.0000; 9903.01.22; 9903.01.31 Mr. Raffaele Natale American Shipping Co. Inc. 250 Moonachie Road Moonachie, NJ 07074 RE: The tariff classification of children’s soft books from China Dear Mr. Natale: In your letter, dated October 20, 2025, you requested a tariff classification ruling on behalf of your client, Kid's Preferred LLC. The ruling was for children’s soft books. The ruling request was returned to you for additional information, which was received November 12, 2025. Product information and samples were submitted for our review. While several samples were submitted, we will focus on five. Item 81369, Winnie The Pooh Deluxe Soft Book, is a textile book printed with images and simple text such as “Easy breezy days” and “Sharing special moments”. The pages are made from cloth with light padding and a crinkly plastic inside. The book comes with two detachable stuffed toys backed with a material that can be attached to hook and loop fasteners on the pages. Item 68639, Peek A Boo! My Happy Farm, is a textile book printed with images and simple text such as “Mama keeps her eggs warm” with an attached stuffed chicken toy, and “Hungry cow eats the grass”. The pages are made from cloth with light padding and a crinkly plastic inside. One page has a circle of plush fabric attached for an additional tactile experience. Item 81370, Stitch Deluxe Soft Book, is a textile book printed with images and simple text such as “Let’s surf” and “Stitch and Angel”. The pages are made from cloth with a light padding and a crinkly plastic inside. The book comes with two detachable stuffed toys backed with a material that can be attached to hook and loop fasteners on the pages. Item 55760 The Very Hungry Caterpillar is a vinyl bath book that is printed with images and simple text, such as “Green leaf” and “Bright sun”. The pages are made from vinyl with a light padding inside. The book is suitable for play in the bath. Item 68549 (no name) is a modified textile book. One cover is the shape of a strawberry and the other is the shape of a lemon. Inside the book is printed with images and simple text, such as “Let’s have fun in the sun!” There is an attached rubber ring for additional play. All of the books are intended for babies, ages 0 and up. 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. Items 80369 and 81370 do consist of articles that are classifiable in different headings – the book and the toys. They are sold together for retail sale. Because of the hook and loop attachments, the toys are used together with the books for learning and enrichment. Therefore, we find that they are “goods put up in sets for retail sale” and the essential character is imparted by the soft book. The applicable subheading for each style of soft book will be 4903.00.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Children's picture, drawing or coloring books. 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 10 percent ad valorem rate of duty. Your merchandise is subject to an excepted subheading as the soft books are considered “informational materials”. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.22, in addition to subheading 4903.00.0000, 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. As the soft books are informational materials, they fall within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e., 9903.01.31, in addition to subheading 4903.00.0000 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 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