The tariff classification of ozone generator bag kits from China

N361383May 27, 2026CLA-2-85:OT:RR:NC:N2:212
CATEGORY: Classification
TARIFF NO.: 8543.70.9860
Rhonda Riley-ThayerSupply Chain Solutions, LLC4607 44th St. SEGrand Rapids, MI 49512RE: The tariff classification of ozone generator bag kits from ChinaDear Ms. Riley-Thayer:In your letter dated
May 8, 2026
, you requested a tariff classification ruling on behalf of your client,Feradyne Outdoors, LLC.There are two items at issue with this request, which are identified as the Scent Crusher Ozone Gear Bag andthe Scent Crusher Ozone Roller Bag. Each product is presented as a kit, which contains a bag and an ozonegenerator. The gear bag is a traditional duffel bag measuring 31”x13”x13” with a shoulder strap, fabrichandles, and a zippered closure. The roller bag measures 34”x20”x13” and is equipped with a collapsiblehandle at one end and wheels at the other. The bag incorporates a zippered closure and fabric handles. Eachbag contains a dedicated pocket for the incorporation of the ozone generator.The ozone generator, referred to as the common generator, consists of Printed Circuit Board Assembly(PCBA), ceramic corona plate, and a rechargeable battery within a plastic enclosure. The front of theenclosure incorporates various control buttons as well as an LED display screen. The subject commongenerator functions by drawing in air and passing it through the corona plate. The plate introduces anelectrical charge to the air, which creates charged oxygen, or ozone. This ozone is used to sterilize andremove odors.The common generator is placed within the designated enclosure within the bag. The user then places theirspecified gear within the bag, such as hunting clothes, and powers on the generator. The generator will thensterilize and remove any odors from the clothing or other articles in the bag. You state that the generator andbag are exclusively sold together and are delivered to the end user in retail packaging. Further, the commongenerator is not available for purchase without the bags.In your request, you suggest that the correct classification for the bags and generator should be 8543.70.9860,Harmonized Tariff Schedule of the United States (HTSUS). We agree.
Classification is determined pursuant to the General Rules of Interpretation (GRIs) of the HTSUS. In ourview, the subject articles meet the definition of “goods put up in sets for retail sale” as it consists of articlesclassified in different headings that are put together to meet a specific need packaged in a manner suitable forsale directly to end users. Due to this fact, we look to the terms of GRI 3 in order to determine the appropriateclassification. GRI 3(a) states that the heading that provides the most specific description shall be preferred toheadings providing a more general description. However, when two or more headings refer to only part of theitems in a composite good or set, those headings are to be regarded as equally specific in relation to thegoods, even if one of them gives a more complete or precise description of the good. As such, they areregarded as equally specific, and classification of the set is to be determined by GRI 3(b) or GRI 3(c) taken inthe appropriate order in which they are set out in GRI 3.GRI 3(b) states, in part, that goods put up in sets for retail sale, which cannot be classified by reference toGRI 3(a), are to be classified as if they consisted of the component that gives them their essential character.Upon examination of the facts presented in this case, it is our view that neither the bag nor the generatorimpart the essential character of the finished set. We must then look to GRI 3(c), which states that the kit isclassified pursuant to the heading that falls last in numerical order within the tariff. The ozone generatorwould fall last in this case within heading 8543, HTSUS.The applicable subheading for the Scent Crusher Ozone Gear Bag and the Scent Crusher Ozone Roller Bagwill be 8543.70.9860, HTSUS, which provides for “Electrical machines and apparatus, having individualfunctions, not specified or included elsewhere in this chapter; parts thereof: Other machines and apparatus:Other: Other: Other: Other.” The general rate of duty will be 2.6% ad valorem.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 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 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.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 Luke LePage at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division