The tariff classification of a bead set from China.

N360885May 11, 2026CLA-2-39:OT:RR:NC:N4:415
CATEGORY: Classification
TARIFF NO.: 3926.90.3500
Ryan LickfeldGeodis USA, LLC5101 South Broad StreetPhiladelphia, PA 19112RE: The tariff classification of a bead set from China.Dear Mr. Lickfeld:In your letter dated
April 21, 2026
, you requested a tariff classification ruling on behalf of your client, CVSPharmacy, Inc.Images were provided in lieu of a sample.The product under consideration is described as a Halloween bead set, item number 646606. It includes 950plastic beads of various sizes and colors and a four-meter length of man-made fiber thread for the consumerto cut to length as needed for use in assembling jewelry items using the included beads such as bracelets ornecklaces. These components will be housed inside a plastic container shaped like a ghost or skull.In your submission, you suggested classification under subheading 9503.00.0074, Harmonized TariffSchedule of the United States (HTSUS), as an activity set. We disagree as we find that the merchandiseconcerned is not principally designed for amusement, but rather to be used for the creation of beaded orjewelry items. Further, it does not contain any toy items. Any amusement this product may provide isincidental to the utilitarian purpose of this item as a beaded article or jewelry making kit. For tariff purposes,this product is not considered to be a toy principally designed for amusement and is therefore precluded fromclassification in heading 9503.Further, you proposed classification under subheading 7117.90.7500, HTSUS. However, these articles areprecluded from the heading because they are not imitation jewelry or articles of personal adornment. Theplastic beads are packaged and presented as decorative craft components rather than wearable jewelry.We look to New York ruling letter N334271, dated August 3, 2023, which addresses a similar style kit onhow to properly classify this bead set.
The applicable subheading for the Halloween bead set, item number 646606, will be 3926.90.3500,Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[o]ther articles of plasticsand articles of other materials of headings 3901 to 3914: [o]ther: [b]eads, bugles and spangles, not strung(except temporarily) and not set; articles thereof, not elsewhere specified or included: [o]ther.” The columnone, general rate of duty is 6.5 percent ad valorem.The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenienceand are subject to change. The text of the most recent HTSUS and the accompanying duty rates are providedat https://hts.usitc.gov/.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 otherduties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to theclassification 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.For further information to assist with the importation process, please refer to the frequently updated CargoSystems Messaging Service (CSMS) messages athttps://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page athttps://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 CBP Regulations (19 CFR 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 Kristopher Burton at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division