The tariff classification of lunch boxes from China

N349867
July 2, 2025
CLA-2-42:OT:RR:NC:N4:441
CATEGORY: Classification
TARIFF NO.: 4202.19.0000; 9903.88.03; 9903.01.24; 9903.01.25
Adam Richards Manhattan Line 24418 Main Street, Suite 410 Carson, CA 90745 RE: The tariff classification of lunch boxes from China Dear Mr. Richards: In your letter dated May 22, 2025, you requested a tariff classification ruling. You have submitted photographs and descriptive literature. Please note, this letter is part of a split ruling. Style Etnop was addressed in New York Ruling N349348. The remaining items will be addressed herein. Styles BMNOP and SLNOP are hinged, metal lunch boxes, each with a handle. They are designed to provide storage, protection, portability, and organization to a child’s lunch. You suggested that styles BMNOP and SLNOP are properly classified under subheading 7310.29.0065, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Tanks, casks, drums, cans, boxes, and similar containers, of iron or steel, for any material, of a capacity not exceeding 50 liters, other, for food products”. We disagree. The lunch boxes are more appropriately classified in Heading 4202. Please see HQ H275864 dated June 17, 2020. The applicable subheading for the metal lunch boxes will be 4202.19.0000, HTSUS, which provides for trunks, suitcases, vanity cases, attaché cases, briefcases, school satchels and similar containers, other. The general rate of duty will be 20 percent ad valorem. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 4202.19.0000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 4202.19.0000, HTSUS, listed above.

Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition to subheading 4202.19.0000, HTSUS, listed above. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading 4202. 19.0000, HTSUS, listed above. The tariffs and additional 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/. 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 Vikki Lazaro at [email protected].
Sincerely,
(for) James Forkan Acting Director National Commodity Specialist Division