The tariff classification of VIP lanyards from China.

N329871 January 3, 2023 CLA-2-49:OT:RR: NC:4:434 CATEGORY: Classification TARIFF NO.: 4911.99.8000; 9903.88.15 Ken Park Amscan Inc. A Party City Holdings Co. 1 Celebration Square Woodcliff Lake, NJ 07677   RE: The tariff classification of VIP lanyards from China. Dear Mr. Park: In your letter, dated December 14, 2022, you requested a tariff classification ruling. A detailed description and photos of the item were submitted for our review. Item #3903434 is the “Malibu Barbie VIP Pass Lanyard.” It consists of a textile lanyard with an attached metal clasp holding a clear PVC plastic card holder. Inserted in the holder is a printed Barbie VIP card. The card is visible through the PVC holder. The card reads, “VIP, Living the Dream Life” with the word “Barbie” in the corner and a faint design of palm trees in the background. Per your submission, the lanyard is 18.5” in length, the card holder is approximately 4” by 6.6” , and the printed card is approximately 3.3” by 2.4”. You state that the merchandise is to be sold in the party goods section of retail stores. Since the item is composed of different materials (lanyard, metal clasp, plastic holder, and printed card), it is considered a composite good for tariff purposes.  The Explanatory Notes (ENs) to the Harmonized Tariff Schedule of the United States (HTSUS), GRI 3(b) (VIII) state that “the factor which determines essential character will vary between different kinds of goods.  It may, for example, be determined by the nature of the materials or components, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the goods.” When the essential character of a composite good can be determined, the whole product is classified as if it consisted only of the material or component that imparts the essential character. In this case, the essential character of the “Malibu Barbie VIP Pass Lanyard” is the printed VIP card, based on the role of the card in relation to the use of the goods. The child wears the lanyard around their neck to display the VIP pass. The applicable subheading for the VIP lanyards will be 4911.99.8000, HTSUS, which provides for “Other printed matter:… Other: Other: Other: Other.” 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. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 4911.99.8000, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty.  At the time of importation, you must report the Chapter 99 subheading, 9903.88.15, in addition to subheading 4911.99.8000, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively. 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, contact National Import Specialist Charlene Miller at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division