The tariff classification of a dog walking kit from China

N363976August 13, 2026CLA-2-85:OT:RR:NC:N4 410
CATEGORY: Classification
TARIFF NO.: 4202.92.9100; 7616.99.5190; 8513.10.2000; 8513.10.4000
Jake WolfordWolfeez53 W 825 SWillard, UT 84340RE: The tariff classification of a dog walking kit from ChinaDear Mr. Wolford:In your letter dated
August 3, 2026
, you requested a tariff classification ruling on a dog walking accessory kitfrom China.The merchandise is referred to as the Walkalong Dog Leash Accessory Set (“kit”) which you described asfollows:The kit is a specialized accessory designed exclusively for use during dog walking. The kit consists of apouch with two lights and attached.Two Type-C charging cables areanaluminum alloy S-climbing hook included in the pouch. All of the items are packed together ready for retail sale. The flashlight is pen-likewith a clip and the safety light is constructed of an oval plastic housing with a red translucent diffusor on oneside containing LED lamps inside. A clip is built into the plastic housing.You explain that the Walkalong pouch is a utility attachment that secures directly to a dog leash viaintegrated clips. It features a neoprene and nylon/spandex textile housing, a dedicated waste bag dispenser,and a small storage compartment for specific pet safety items (such as a safety light or pen). The alkalongWpouch lacks any built-in handle, strap, or standalone carrying mechanism. The product is never worn orcarried independently by the human owner; it relies entirely on being suspended from a leash, while the userholds the leash handle.You suggest that the kit should be classified as subheading 4201.00.3000, Harmonized Tariff a set underSchedule of the United States (HTSUS), which provides for saddlery and harness for any animal (includingtraces, leads, knee pads, muzzles, saddle cloths, saddle bags, dog coats and the like), of any material: Dogleashes, collars, muzzles, harnesses and similar dog equipment; or alternatively, under subheading4202.92.3131, HTSUS, which provides for travel, sports and similar bags, with outer surface of textilematerials, other, of man-made fibers, other; pursuant to General Rules of Interpretation (GRI) 3(b).
We disagree.Classification under the HTSUS is made in accordance with the General Rules of Interpretation (GRIs). TheExplanatory Notes, which constitute the official interpretation of the HTSUS at the international level, statein Note X to GRI Rule 3(b) that the term “goods put up in sets for retail sale” means goods that: (a) consist ofat least two different articles which are, prima facie, classifiable in different headings; (b) consist of articlesput up together to meet a particular need or carry out a specific activity; and (c) are put up in a mannersuitable for sale directly to users without repacking.In this instance, the four items in the kit are classifiable in different headings and are put up in a mannersuitable for sale directly to users without repacking. However, there is no evidence that these items are put uptogether to meet a particular need or carry out a specific activity. The pouch (with the S-climbing hook) has adefined purpose as a container for carrying or attaching numerous different items. The lights are to provideillumination when used in darkness or low light conditions and are unrelated to, and independent of thepouch and S climbing hook. Based on the available information, there is no particular need or any specificactivity which these items would function together to meet or carry out. As such, the items do not satisfy thecriteria of GRI 3(b) as goods put up in sets for retail sale and are classified individually.Further, the Walkalong pouch is used to contain personal effects while walking an owner’s dog. It securesdirectly to the dog’s leash and is constructed of man-made textile material, and it features a waste bagdispenser and a small storage compartment. You suggest classification of the Walkalong pouch in heading4201, HTSUS, which provides for “Saddlery and harness for any animal (including traces, leads, knee pads,muzzles, saddle cloths, saddle bags, dog coats and the like), of any material.” However, the pouch itself is notdirectly used to constrain the dog as would a leash. It is used to provide storage, protection, portability, andorganization to the owner’s belongings while walking the dog.It attaches to the leash simply for convenience. Accordingly, the applicable subheading for the Walkalong pouch will be 4202.92.9100, HTSUS, whichprovides for “Trunks, suitcases, vanity cases, attache cases, briefcases, school satchels, spectacle cases,binocular cases, camera cases, musical instrument cases, gun cases, holsters and similar containers;…Other:With outer surface of sheeting of plastic or of textile materials, Other: Other: With outer surface of textilematerials: Of man-made fibers (except jewelry boxes of a kind normally sold at retail with their contents).” The general rate of duty will be 17.6 percent ad valorem.The applicable subheading for the S-climbing hook will be 7616.99.5190, HTSUS, which provides for“Other articles of aluminum: Other: Other: Other: Other: Other.” The general rate of duty will be 2.5 percentad valorem.The applicable subheading for the flashlight will be 8513.10.2000, HTSUS, which provides for “Portableelectric lamps designed to function by their own source of energy (for example, dry batteries, storagebatteries, magnetos)…: Lamps: Flashlights.” The general rate of duty will be 3.5 percent ad valorem.The applicable subheading for the safety light will be 8513.10.4000, HTSUS, which provides for “Portableelectric lamps designed to function by their own source of energy (for example, dry batteries, storagebatteries, magnetos)…: Lamps: Other.” The general rate of duty will be 12.5 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 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 Michael Chen at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division