The country of origin of the LEGO “Stranger Things” “The Upside Down” building blocks kit

N352110
September 2, 2025
OT:RR:NC:N3:356
CATEGORY: Origin Ben Shaun 12395941 Canada, Inc. 84 Moorehouse Drive Scarborough M1V 2E1 Canada RE: The country of origin of the LEGO “Stranger Things” “The Upside Down” building blocks kit Dear Mr. Shaun: In your letter dated August 7, 2025, you requested a ruling on the proper country of origin declaration for the LEGO “Stranger Things” “The Upside Down” building blocks kit, Item #75810. Based on internet research, Item #75810 includes plastic blocks and other components (for example, figurines representing human characters). An individual can use these pieces to build a completed item that depicts a house/scene from the television program “Stranger Things.” A photograph of the country of origin marking of Item #75810 was submitted with your inquiry. The retail box is marked as follows: “Components made in Denmark, Hungary, Mexico, China, Indonesia, the USA, and the Czech Republic.” The country of origin marking of the good is not at issue; your inquiry concerns only how to properly declare the country of origin at time of entry. General Note (GN) 3, Harmonized Tariff Schedule of the United States (HTSUS) addresses the commingling of goods. GN 3(f) states, in pertinent part: (i) Whenever goods subject to different rates of duty are so packed together or mingled that the quantity or value of each class of goods cannot be readily ascertained by customs officers (without physical segregation of the shipment or the contents of any entire package thereof), by one or more of the following means: (A) sampling, (B) verification of packing lists or other documents filed at the time of entry, or (C) evidence showing performance of commercial settlement tests generally accepted in the trade and filed in

such time and manner as may be prescribed by regulations of the Secretary of the Treasury, the commingled goods shall be subject to the highest rate of duty applicable to any part thereof unless the consignee or his agent segregates the goods pursuant to subparagraph (f)(ii) hereof. Item #75810 consists of components subject to tariffs that vary depending on their countries of origin. The components are commingled in the retail box, and it is essentially impossible to either identify the country of origin of each individual component, or obtain information on the number of components from each country that are included in the box. Therefore, pursuant to GN 3(f), HTSUS, Item #75810 will be subject to the highest rates of duty applicable to any of the components, which are those associated with China. Accordingly, a country of origin of China should be declared at entry. The holding set forth above is correct as of this ruling’s issuance, and 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 Maryalice Nowak at [email protected].
Sincerely,
(for) Denise Faingar Acting Director National Commodity Specialist Division