The tariff classification of a DIY Canvas Painting Kit from China

N361728June 12, 2026CLA-2-32:OT:RR:NC:N3:136
CATEGORY: Classification
TARIFF NO.: 3213.10.0000
Rebecca MitchellSkinnydip LtdAcademic House, 24 - 28 Oval RoadLondon NW1 7DJUnited KingdomRE: The tariff classification of a DIY anvas ainting iCPKt from ChinaDear Ms. Mitchell:In your letter dated
May 22, 2026
, you requested a tariff classification ruling on a DIY anvas ainting iCPKt.In your submissionIY anvas ainting i, the subject product is identified as a DCPKt. This activity kit isis imported in a condition suitable for retail sale.The kit intended for children ages three and above and issix acrylic pods in assorted colors, one paintbrush,comprised of paint one small canvas with an outlinedimage, one small plastic easel, and a sheet of stickers. All of the kit’s components are intended to be usedtogether, to creatively paint and decorate the canvas.The Explanatory Notes to the Harmonized Tariff System, although not legally binding, provide guidance inthe interpretation of the Harmonized Commodity Description and Coding System at the international level.Explanatory Note X to GRI 3 (b) provides that the term "goods put up in sets for retail sale" means goodsthat; (a) consist of at least two different articles which are, prima facie, classifiable in different headings; (b)consist of articles put up together to meet a particular need or carry out a specific activity; and (c) are put upin a manner suitable for sale directly to users without re-packing. Goods classifiable under GRI 3 (b) areclassified as if they consisted of the material or component which gives them their essential character, whichmay be determined by the nature of the material or component, its bulk, quantity, weight or value, or by therole of a constituent material in relation to the use of the article. GRI 3 (c) provides that when goods cannotbe classified by reference to GRI 3 (a) or 3 (b), they are to be classified in the heading that occurs last innumerical order among those which equally merit consideration.IY anvas ainting iwill be The DCPKt classified as a set for tariff classification purposes in accordance with GRI 3(b), with the essential characterimparted by the paints and paint brush (colors in sets); we believe these components are indispensable to theproduct’s primary function and use, which is the activity of painting.
The applicable subheading for the IY anvas ainting i will be 213.10.0000, Harmonized tariff ScheuleDCPKt3of the United States (HTSUS), which provides for Artists’, students’ or signboard painters’ colors, modifyingtints, amusement colors and the like, in tablets, tubes, jars, bottles, pans or in similar forms or packings:Colors in sets. The general rate of duty will be 6.5 percent ad valorem on the entire set.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.This merchandise may be subject to the requirements of the Toxic Substances Control Act (TSCA), whichare administered by the U.S. Environmental Protection Agency. Information on the TSCA can be obtained bycontacting the EPA at 1200 Pennsylvania Avenue, N.W., Mail Code 70480, Washington, D.C., by telephoneat (202) 554-1404, or by visiting their website at www.epa.govThe 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 Nuccio Fera at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division