RE: The tariff classification of a diving mask from Greece

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364825 September 28, 2026 CLA-2-95:OT:RR:NC:N4:462 CATEGORY: Classification TARIFF NO.: 9506.29.0080 Benjamin Lair Paragon Dive Group LLC 2951 North Swan Road Tucson, AZ 85712 RE: The tariff classification of a diving mask from Greece Dear Mr. Lair, In your letter dated September 3, 2026, you requested a tariff classification ruling. Images and product literature were submitted in lieu of a sample. The article under consideration is the “divePRO SCUBA,” an augmented-reality (AR) diving mask with an integrated electronic dive computer. The diving mask is comprised of a single tempered-glass lens, a soft-silicone skirt, and an adjustable strap. The mask incorporates an electronic module which provides an AR optical display of dive parameters within the diver’s field of view and performs the functions of a dive computer, such as measuring and displaying depth, elapsed dive time, decompression requirements, ascent information, temperature, battery status, and dive alerts using the Bühlmann ZHL-16C algorithm. The electronic module, which includes a pressure/depth sensor, Long-Term Evolution (LTE) module, Near Field Connection (NFC) module, Global Navigation Satellite System (GNSS) module, LiPo battery, and AR optical display, is embedded within the mask frame and is not a separate, detachable unit. Before use, the mask must be paired to the divePRO app using Bluetooth technology. The mask will be imported and sold together with a magnetic charging cradle with USB-C cable, a protective case, a quick-start card, and a safety and regulatory information booklet. The AR diving mask is a composite good that incorporates both a diving mask and a dive computer, each classifiable under a different heading of the Harmonized Tariff Schedule of the United States (HTSUS). GRI 1 cannot be used as a basis for classification. GRI 3(b) provides that mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale shall be classified as if they consisted of the material or component which gives them their essential character. The essential character of an item 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. It is the opinion of this office that the diving mask imparts the essential character to the article. The mask is likely to provide the consumer with the motivation to purchase. An individual looking for a diving mask may be further enticed by the dive computer feature, however it is unlikely that the converse would be true. Additionally, the diving mask can function on its own, even if the dive computer were to stop working, whereas the dive computer would be useless if the mask could not be used. In your submission, you suggest classification under subheading 8543.70.9860, HTSUS. We disagree. Though we agree that a dive computer, when presented on its own, would be classified within heading 8543, HTSUS, we disagree that the subject mask has the essential character of a dive computer for the reasons stated above. Further, the physical characteristics of the mask make it recognizable as a dive mask regardless of the incorporation of the electronic functions. As such, the device is not primarily electrical, a requisite criterion for inclusion within heading 8543, HTSUS. Based upon this, classification within the suggested heading is not applicable. The applicable subheading for the “divePRO SCUBA” diving mask will be 9506.29.0080, HTSUS, which provides for “Articles and equipment for general physical exercise, gymnastics, athletics, other sports (including table-tennis) or outdoor games, not specified or included elsewhere in this chapter; swimming pools and wading pools; parts and accessories thereof: Water skis, surf boards, sailboards and other water-sport equipment; parts and accessories thereof: Other: Other.” The 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 Frequently Asked Questions on the Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ. 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 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, please contact National Import Specialist Sandra Walia at sandra.s.walia@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division