The tariff classification of a pumpkin decorating kit from China

N361665June 5, 2026CLA-2-96:OT:RR:NC:CEE008:N4:462
CATEGORY: Classification
TARIFF NO.: 9608.20.0000
Ryan LickfeldGeodis USA LLC5101 South Broad StreetPhiladelphia, PA 19112RE: The tariff classification of a pumpkin decorating kit from ChinaDear Mr. Lickfeld:In your letter dated
May 20, 2026
, you requested a tariff classification ruling on behalf of your client, CVSPharmacy, Inc.Samples were provided and will be retained as requested.The product under consideration is described as the “Hydro Dip Mini Pumpkin Kit,” item number 646940. The kit consists of four water-soluble hydro dip sheets made of polyvinyl alcohol (PVA) each measuring fiveinches by five inches, five alcohol-based markers, two Halloween-themed patterns/designs printed on paper,two mini binder clips, and a set of instructions packaged together in a retail box.The user secures a hydro dip sheet to the top of one of the patterns using the binder clips, then fills in the design using the blue, purple,red, black and green markers.They lay the water-soluble hydro dip film on a water surface provided thenand dip a mini pumpkin down through the film, then scoop it back up, creating a U-shaped path back to thewater’s surface and transferring the pattern onto the pumpkin.The “Hydro Dip Mini Pumpkin Kit” is considered a set for tariff purposes. T markers predominate byheweight and value and account for the vast majority of the use of the set, impart the essentialtherefore they character, GRI 3(b) noted.The applicable subheading for the “Hydro Dip Mini Pumpkin Kit,” item number 646940, will be9608.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Ball pointpens; felt tipped and other porous-tipped pens and markers; fountain pens, stylograph pens and other pens;duplicating styli; propelling or sliding pencils (for example, mechanical pencils); pen-holders, pencil-holdersand similar holders; parts (including caps and clips) of the foregoing articles, other than those of heading9609: Felt tipped and other porous-tipped pens and markers.” The rate of duty will be 4 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 at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions onthe Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.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 Sandra Walia at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division