N323568

N323568 January 19, 2022 CLA-2-39:OT:RR:NC:N4:415 CATEGORY: Classification TARIFF NO.: 3926.90.9985; 9903.88.15 Ms. Macrina Garza PETCO 654 Richland Hills Drive San Antonio, TX 78245 RE: The tariff classification of pet collar accessories from China. Dear Ms. Garza: In your letter dated January 6, 2022, you requested a tariff classification ruling. Images were submitted in lieu of samples. The products under consideration are described as pet collar accessories with the principal use of holding Apple AirTag tracking devices. Two versions were submitted. The first, “Product A,” consists of a red silicone plastic tag holder that is round and features a cavity to fit the AirTag. It includes a metal ring that runs through a molded loop at the top of the accessory, allowing it to be attached to a pet collar. As “Product A” is considered a composite article, we are of the opinion that the silicone plastic component would impart the essential character as it holds the AirTag, General Rule of Interpretation 3(b) noted. The second version, “Product B,” consists of a blue silicone plastic tag holder that features a cutout slot in the shape of a dog bone, permitting the AirTag to be inserted into the body of the accessory. Molded loops are on either side of the holder, so a collar can be fed through the product. This holder is wholly made of silicone plastic. As both AirTag Holders, “Product A” and “Product B,” would be considered articles of plastic, and as they are not more specifically provided for elsewhere, the applicable subheading will be 3926.90.9985, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther.” The column one, general rate of duty is 5.3 percent ad valorem. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 3926.90.9985, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 3926.90.9985, HTSUS, listed above. The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively. 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/current. Please note that modifications to the Harmonized Tariff Schedule of the United States (HTSUS) [to align the HTSUS on the 2022 version of the Harmonized Commodity Description and Coding System] pursuant to Section 1206 of the Omnibus Trade and Competitiveness Act of 1988 are forthcoming. These modifications, made by Presidential Proclamation 10326 and set forth in Annexes I, II.A, and II.B of U.S. International Trade Commission Publication 5240, will be effective on January 27, 2022. To the extent that the modifications to the HTSUS impact the classification of the merchandise subject to this ruling, you may submit a new ruling request at that time. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR 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, contact National Import Specialist Kristopher Burton at kristopher.burton@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division

Apple AirTag tracking devices.Two versions were submitted. The first, “Product A,” consists of a red silicone plastic tag holder that is round and features a cavity to fit the AirTag. It includes a metal ring that runs through a molded loop at the top of the accessory, allowing it to be attached to a pet collar. As “Product A” is considered a composite article, we are of the opinion that the silicone plastic component would impart the essential character as it holds the AirTag, General Rule of Interpretation 3(b) noted.The second version, “Product B,” consists of a blue silicone plastic tag holder that features a cutout slot in the shape of a dog bone, permitting the AirTag to be inserted into the body of the accessory. Molded loops are on either side of the holder, so a collar can be fed through the product. This holder is wholly made of silicone plastic.As both AirTag Holders, “Product A” and “Product B,” would be considered articles of plastic, and as they are not more specifically provided for elsewhere, the applicable subheading will be 3926.90.9985, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther.” The column one, general rate of duty is 5.3 percent ad valorem.Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 3926.90.9985, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 3926.90.9985, HTSUS, listed above.The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of