The tariff classification of a 3D Pokémon model from China

N362089
June 18, 2026
CLA-2-48:OT:RR:NC:N5:130
CATEGORY: Classification
TARIFF NO.: 4823.90.6700
Ms. Ann Lawrence Dollar General Corp. 100 Mission Ridge Goodlettsville, TN 37072 RE: The tariff classification of a 3D Pokémon model from China Dear Ms. Lawrence: In your letter, dated June 4, 2026, you requested a binding tariff classification ruling on a three-dimensional Pokémon model. Product information and a sample were submitted for our review. The product under consideration is SKU #44712401, Pokémon 3D Puzzle Model Kit. The item is a 9.2”-high, three-dimensional model of a Pokémon character that the user assembles. The model is constructed from die-cut pieces with tab and slot assembly. The pieces are constructed of a sheet of polystyrene foam sandwiched between two sheets of printed, coated paperboard. The foam gives the pieces dimension and stability. The paperboard provides stability and the decorative printing imparts the consumer interest. You suggest in your letter that the model is classified in subheading 9503.00.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for puzzles of all kinds. We disagree. The item is not a puzzle as there is no challenge to be solved. This is a model with complete instructions directing the user how to assemble all the pieces in designated locations. Therefore, it is merely a model classifiable by the constituent material. Because the model is constructed of a combination of paper and polystyrene foam, both of which are classifiable in different headings, this is considered to be a composite good, and classification is determined by essential character. The Explanatory Notes (EN) to the Harmonized System, General Rules of Interpretation (GRI) 3(b) (VIII), state that “the factor which determines essential character will vary between different kinds of goods. It may for example, be determined by the nature of the materials or components, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the goods.” When the essential character of a composite good can be determined, the whole product is classified as if it consisted only of the material or component that imparts the essential character to the composite good.

The essential character of the model is imparted by the printed, coated paper. The foam merely provides stability and body, whereas the paper and printing impart the commercial appeal of the model. Therefore the model will be classified according to the paper content. The applicable subheading of SKU #44712401, Pokémon 3D Puzzle Model Kit will be 4823.90.6700, HTSUS, which provides for Other paper, paperboard, cellulose wadding and webs of cellulose fibers, cut to size or shape; other articles of paper pulp, paper, paperboard, cellulose wadding or webs of cellulose fibers: Other: Other: Other: Of coated paper or paperboard: 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 Laurel Duvall at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division