RE: The tariff classification of a flexible straw bracelet from China

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364333 September 1, 2026 CLA-2-83:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 8307.10.6060 Jorge Carpio Wristraw, Inc. 2108 North Street, Suite N Sacramento, CA 95816 RE: The tariff classification of a flexible straw bracelet from China Dear Mr. Carpio: In your letter dated August 16, 2026, you requested a tariff classification ruling. Informational material was submitted with your request. The merchandise under consideration is a flexible straw bracelet described as the “Wristraw Signature.” The item is a combination wrist bracelet and a flexible straw for consuming beverages and is available in three sizes: 18 centimeters (cm), 19 cm, and 22 cm. The primary components are a flexible corrugated steel tube and a silicon containment tube. The flexible steel tube is inserted into the silicon tube and held in place by two steel plugs at each end. The entire item can then be wrapped around a person’s wrist to be worn like a bracelet. When needed, the item can be removed from the wrist, and the flexible steel tube can be removed from the containment tube and be used as a drinking straw. In your submission you suggest that this article should be classified under Harmonized Tariff Schedule of the United States (HTSUS) General Rule of Interpretation (GRI) 3(b) which provides for “Mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale, which cannot be classified by reference to 3(a), shall be classified as if they consisted of the material or component which gives them their essential character.” We disagree. We note that the straw bracelet has two distinct uses, it can function as a drinking straw or a bracelet making the essential character indistinguishable. This makes it possible to classify this article under heading 7117, HTSUS, which provides for “Imitation jewelry” and heading 8307, HTSUS, which provides for “Flexible tubing of base metal, with or without fittings.” GRI 3(c) provides that “when goods cannot be classified by reference to 3(a) or 3(b), they shall be classified under the heading which occurs last in numerical order.” Since the essential character is indistinguishable, the article cannot be classified under GRI 3(b). In accordance with the GRIs taken in order, the straw bracelet will be classified under GRI 3(c) by operation. Heading 7117 is precluded because heading 8307 is the last heading in numerical order. Therefore, the straw bracelet will be classified under heading, 8307, HTSUS.
The applicable subheading for the flexible straw bracelet will be 8307.10.6060, HTSUS, which provides for “Flexible tubing of base metal, with or without fittings: Of iron or steel: Other: Other.” The general rate of duty will be 3.8 percent 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 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 Matthew Gay at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division