The tariff classification of a cooling wristband from China.

N322971 December 15, 2021 CLA-2-71:OT:RR:NC:N4:462 CATEGORY: Classification TARIFF NO.: 7117.90.7500 Ted Conlon Fourstar Group USA, Inc. 189 Main Street, Suite 31 Milford, MA 01757 RE: The tariff classification of a cooling wristband from China. Dear Mr. Conlon: In your letter dated November 29, 2021, you requested a tariff classification ruling. Photos and descriptive literature were received. Item number: 64409399A is described as a cooling wristband. It is comprised of a silicone wristband and a high-density polyethylene (HDPE) cooling pack containing liquid gel: 97.8% water, 2% glycerin, 0.2% CMC (carboxymethyl cellulose). The silicone wristband bracelet, resembling a wristwatch but with no time function whatsoever, measures 230 mm long x 25 mm wide and the cooling pack measures 36.1 mm x 23.3 mm. The wristband has a rectangular opening to accept the hard plastic gel pack. The consumer places the cooling pack in the freezer for a desired time to cool or freeze the contents. The consumer then inserts the cooling pack into the opening into the wrist strap and wears it as a bracelet with the cooling pack touching their skin. The Explanatory Notes (ENs) to the Harmonized Tariff Schedule of the United States (HTSUS) constitute the official interpretation of the tariff at the international level. EN XII to General Rule of Interpretation (GRI) 3(c) provides in part: “when goods cannot be classified by reference to Rule 3(a) specific description or 3(b) essential character, they are to be classified in the heading which occurs last in numerical order among those which equally merit consideration in determining their classification.” The cooling wristband is made up of a silicone wristband and a cooling pack. It is considered a composite good for tariff purposes. It is the opinion of this office that no one element provides the essential character. Therefore, the classification would be provided from the item last in tariff, which, in this case, is the silicone wristband, GRI 3(c) noted. The applicable subheading for item number: 64409399A will be 7117.90.7500, HTSUS, which provides for “Imitation jewelry: Other: Other: Valued over 20 cents per dozen pieces or parts: Other: Of plastics.” The rate of duty will be free. 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 on the World Wide Web at https://hts.usitc.gov/current. This ruling is being issued under the provisions of Part 177 of the Customs 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 Sandra Sary at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division