RE: The tariff classification of Aqua Doodle Books 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 N364453 September 3, 2026 CLA-2-49:OT:RR:NC:N4:434 CATEGORY: Classification TARIFF NO.: 4903.00.0000 Anna Matsushima PILOT Corporation 6-21, Kyobashi -Chome Chuo-ku Tokyo 104-8304 Japan RE: The tariff classification of Aqua Doodle Books from China Dear Ms. Matsushima: In your letter dated August 21, 2026, you requested a tariff classification ruling on “Aqua Doodle Books.” A description and four samples of the “Aqua Doodle Book” were submitted for our review. The items under consideration are “Aqua Doodle Books.” Each of the samples received features a different theme: Farm, Zoo, Favorite Foods or Vehicles. Each book is constructed of five paperboard sheets that are spiral-bound at the top edge, with a “coloring pen” secured to the book by an elastic loop. The upper portion of the inside pages is printed with instructions and guided play activities, while the bottom portion is printed with a full-color image that pertains to the theme of the book. Each book contains four colored images covered with a layer of white coating. When the coloring pen is filled with water, a child can use it to apply water to the white coating to reveal the hidden images. As the pages dry, the white coating becomes opaque again, allowing for repeated use. Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is made in accordance with the General Rules of Interpretation (GRIs). The Explanatory Notes, which constitute the official interpretation of the HTSUS at the international level, state in Note (X) to GRI Rule 3 (b) that the term "goods put up in sets for retail sale" means goods that: (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 up in a manner suitable for sale directly to users without repacking. Goods classifiable under GRI 3(b) are classified as if they consisted of the material or component which gives them their essential character, which may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the article.
The “Aqua Doodle Book” and the coloring pen are classifiable in different headings. They are used together to reveal the hidden themed images and are packaged together for retail sale. Therefore, the “Aqua Doodle Book” and the coloring pen are “goods put up in sets for retail sale.” The essential character is imparted by the “Aqua Doodle Book.” The ENs to heading 4903, in their pertinent part state: This heading is restricted to those picture books clearly compiled for the interest or amusement of children or for guidance in their first steps of primary education, provided the pictures form the principal interest and are not subsidiary to the text (see Note 6 to this Chapter). This heading also includes children’s drawing or colouring books. They also include similar books with “invisible” outlines or colour which can be made visible by rubbing with a pencil or applying water with a paint brush… The “Aqua Doodle Books” fall within this description. The applicable subheading for the “Aqua Doodle Books” will be 4903.00.0000, HTSUS, which provides for Children's picture, drawing or coloring books. 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 Susana Li at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division