The tariff classification of a string art kit from China

N352616June 11, 2026CLA-2-54:OT:RR:NC:N2:352
CATEGORY: Classification
TARIFF NO.: 5404.19.8020
Mr. Maksim MitsilovichAmpaxar Group Inc.30 N Gould Street, Suite NSheridan, WY 82801RE: The tariff classification of a string art kit from ChinaDear Mr. Mitsilovich:In your letter dated
August 19, 2025
, you requested a tariff classification ruling for a string art kit. Acomplete sample kit was providedhe yarn component was sent for laboratory analysis.The remaining kit. T components will be retained for reference purposes.The subject merchandise, described as the Let’s String Kit," consists of a multi-component arts, SKU# LS1"and crafts assembly kit packaged together for individual retail sale.t is a art kit that allows you to turn any Inpicture or photo into string .The kit contains: a ooden baseart w, measuring 19.5 × 19.5 × 0.375 inches,pre-fitted with 240 metal nails arranged in a precise circle spool of filament yarn, weighing; amononylon approximately 150 grams; a dedicated wooden spool bracket designed nto attach to the main wooden base; aadjustable smartphone support stand; a structural cardboard retail container engineered to deploy as awooden wsoftware that processesorking artist's easel; a step-by-step instruction manual; and access to online uploaded photos to create interactive, voiced, step-by-step guide .ou state thatan to complete the project Ythis item is not a toy and is not intended for use by children under 14 years of age.According to the U.S. Customs and Border Protection Laboratory (CBP Laboratory) analysis, the samplemarked "Black yarn on Green Plastic Support" weighs 148.0 grams on its support. The yarn is a single,continuous nylon monofilament that is untwisted, untextured, and not elastomeric. The CBP Laboratoryanalysis indicates a cross-sectional measurement of 0.154 mm, linear density of 228 decitex (23 tex/205denier), and tenacity of 77.53 centinewtons per tex (cN/tex).Under the terms of Note 4 (A)(a)(i) to Section XI, Harmonized Tariff Schedule of the United States(HTSUS), the yarn does not meet the definition of “put up for retail sale” because its gross weight on thesupport exceeds 85 grams.
The "Let’s String Kit," is a composite good consisting of articles of wood (Heading 4421) and single yarncomposed of nylon monofilament (Heading 5404). General Rule of Interpretation (GRI) 1, HTSUS, states inpart that for legal purposes, classification shall be determined according to the terms of the headings, anyrelative section or chapter notes and, unless otherwise required, according to the remaining GRI’s taken inorder. Goods that are, prima facie, classifiable under two or more headings, are classifiable in accordancewith GRI 3. GRI 3(a) states that the heading which provides the most specific description shall be preferredto headings providing a more general description. However, when two or more headings refer to part only ofthe items in a composite good, those headings are to be regarded as equally specific in relation to the goods,even if one of them gives a more complete or precise description of the good. As such, they are regarded asequally specific and classification of the composite good is to be determined by GRI 3(b) or GRI 3(c). GRI3(b) states in part that composite goods, which cannot be classified by reference to GRI 3(a), are to beclassified as if they consisted of the component which gives them their essential character. GRI 3(c) providesthat when goods cannot be classified by reference to GRI 3(a) or 3(b), they are to be classified in the headingthat occurs last in numerical order among the competing headings which equally merit consideration. Wefind that the essential character of the overall product cannot clearly be ascribed to a single material.Therefore, pursuant to General Rule of Interpretation 3(c), HTSUS, the string art kit will be classifiable underheading 5404, HTSUS, which occurs last in numerical order among those which equally merit consideration.The applicable subheading for SKU #LS1, described as the “Let's String Kit,” will be 5404.19.8020, HTSUS,which provides for “Synthetic monofilament of 67 decitex or more and of which no cross-sectionaldimension exceeds 1 mm; strip and the like (for example, artificial straw) of synthetic textile materials of anapparent width not exceeding 5 mm: Monofilament: Other: Other: of nylon or other polyamides.” The rate ofduty will be 6.9 percent ad valorem.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, 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 eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.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/.For further information to assist with the importation process, please refer to the frequently updated CargoSystems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies.The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Nicole Rosso at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division