The tariff classification of Pokémon trading cards from Japan

N359352 March 16, 2026 CLA-2-95:OT:RR:NC:N4:424 CATEGORY: Classification TARIFF NO.: 9504.40.0000 Aaron Hutman Pillsbury Winthrop Shaw Pittman LLP 1200 Seventeenth Street, NW Washington, DC 20036 RE: The tariff classification of Pokémon trading cards from Japan Dear Mr. Hutman: In your letter dated March 2, 2026, you requested a tariff classification ruling on behalf of your client, Collectors Inc. Photographs and descriptions of 3 Pokémon trading cards were submitted with your inquiry. Printed on standard card stock, these cards measure approximately 63mm x 88mm. Each features unique artwork and game information, packaged individually in a clear plastic sleeve or rigid case. You state that the 3 Pokémon cards are to be collector’s items and not to be used in play. Notwithstanding the stated intent of the importer, it does not alter the identity of the commodity nor its essential character and designated purpose. By design, the Pokémon cards function as game pieces for the competitive strategic Pokémon Trading Card Game. In your letter, you suggested that the lithographically printed Pokémon trading cards are classifiable in subheading 4911.99.6000, Harmonized Tariff Schedule of the United States (HTSUS), we disagree. Chapter 49 Notes 1(c) states, this chapter does not cover playing cards or other goods of Chapter 95, therefore, classification in Chapter 49 is precluded. Chapter 95 Legal Note 3 states “….parts and accessories which are suitable for use solely or principally with articles of this chapter are to be classified with those articles.” The Pokémon cards are specially designed and marketed to be used for game play and are a “part” of the Pokémon Trading Card Game, therefore, the cards would be classified in the same provision. Based on past precedence of similar merchandise, and consistent with N352819 dated September 11, 2025, we are of the opinion that the 3 Pokémon trading cards are game pieces classifiable in subheading 9504. The applicable subheading for the Pokémon trading cards will be 9404.40.0000, HTSUS, which provides for “Video game consoles and machines, table or parlor games…: Playing cards. The column one, general rate of duty will be Free. The 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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 Irene Tsiavos at irene.tsiavos@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division