The tariff classification of a tracing projector from China

N360179 April 6, 2026 CLA-2-90:OT:RR:NC:N1:105 CATEGORY: Classification TARIFF NO.: 9008.50.1000 Ryan Lickfeld Geodis USA LLC 5101 S Broad Street Philadelphia, PA 19112 RE: The tariff classification of a tracing projector from China Dear Mr. Lickfeld: In your letter dated March 30, 2026, on behalf of your client, CVS Pharmacy, Inc., you requested a tariff classification ruling. Descriptive literature was provided for our review. The item under consideration is described as a tracing projector (item 736816), which is a projecting art set designed for children aged 3 and older. The set includes a compact plastic projector light and two interchangeable plastic disks. The user inserts and rotates the disks to project images of Disney characters onto paper. The set also provides a plastic tracing marker with ink, enabling users to trace the projected characters, along with 14 blank paper tracing sheets. In your request, you suggest classification for the tracing projector as a toy in subheading 9503.00.0073, Harmonized Tariff Schedule of the United States, (HTSUS). We disagree. The item is not simply designed to amuse children but instead to allow the user to trace an enlarged drawing of a character. This projection function is specifically provided for in heading 9008, HTSUS. Therefore, heading 9503 is excluded from consideration. Accordingly, the applicable subheading for the tracing projector (item 736816) will be 9008.50.1000, HTSUS, which provides for “Image projectors, other than cinematographic; photographic (other than cinematographic) enlargers and reducers; parts and accessories thereof: Projectors, enlargers and reducers: Slide projectors.” The general rate of duty will be 7 percent ad valorem. 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division