The tariff classification of a scratch art craft kit from China

N358430
March 3, 2026
CLA-2-49:OT:RR:NC:N4:434
CATEGORY: Classification
TARIFF NO.: 4911.91.4040
Krista Fedon OOLY, LLC. 5607 Palmer Way Carlsbad, CA 92010 RE: The tariff classification of a scratch art craft kit from China Dear Ms. Fedon: In your letter dated February 2, 2026, you requested a tariff classification ruling on a scratch art craft kit. Photos and a detailed description were submitted for our review. The product under consideration is item #161-203, the Mini Scratch & Scribble Window Banner Kit – Garden. The kit includes six printed, die-cut plastic scratch cards, one wooden scratch tool, one printed instruction sheet, and one colored polyester string, all packaged together inside a cardboard box. The six cards feature color illustrations of a hummingbird, a dragonfly, a snail, a toad, two butterflies, and a bee, along with additional embellishments to further decorate each picture. Each card is coated with a black scratch-off layer, with white printed line art outlining the illustrations beneath. The double-ended wooden tool, measuring approximately 137 millimeters in length, is used to scratch along the printed line art, removing the coating to reveal the picture below. The colored string, measuring approximately 50 inches in length, is used to thread through holes in the cards to assemble them into a banner. The scratch art kit consists of multiple articles classifiable under separate headings. It is packaged for retail sale. The components of the kit carry out a specific activity. This kit therefore meets the term “goods put up in sets for retail sale”. We find that the six illustrated coated cards with line art confer the essential character of the set. The printed color illustrations are the focal point of the set and predominate in quantity, use, and presumably in value, over the wooden tool, instruction sheet, and string. The General Explanatory Notes to Chapter 49, HTSUS, provide in pertinent part: “… this Chapter covers all printed matter of which the essential nature and use is determined by the fact of its being printed with motifs, characters or pictorial representations...” This describes the printed scratch art cards. The applicable subheading for item# 161-203, Mini Scratch & Scribble Window Banner Kit – Garden, will be 4911.91.4040, HTSUS, which provides for Other printed matter, including printed pictures and

photographs: Other: Pictures, designs and photographs: Printed not over 20 years at time of importation: Other: Other: Other. The general rate of duty will be free. 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, 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 either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems 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 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 Susana Li at [email protected].
Sincerely,
(for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division