Classification conclusion
Human-form play dolls are classified by supported age range in the United States. Review base duty, China Section 301, ASTM F963, CPC and CPSC eFiling.
| Field | Conclusion |
|---|---|
| Proposed HTS code | 9503000073 — Children's products intended for ages 3 to 12; representative play-doll code |
| Jurisdiction | United States |
| Tariff edition | HTSUS 2026 |
| Rules applied | GIR/GRI 1 and 6 |
| Confidence | High when the entered merchandise matches the stated facts |
| Condition | A complete new human-form doll, dressed or undressed, principally designed as a children's plaything. |
U.S. HTSUS classification and duty at a glance
This guide covers a complete human-form doll, dressed or undressed, imported as a new toy. U.S. statistical reporting depends primarily on the youngest intended age supported by the design, labeling, packaging and marketing.
| Product facts | HTSUS reporting number | Column 1 General | Column 2 |
|---|---|---|---|
| Children's doll, intended for ages 3 through 12 | 9503.00.0073 | Free | 70% |
| Children's doll, intended for children under 3 | 9503.00.0071 | Free | 70% |
| Non-children's product, such as a substantiated adult collectible | 9503.00.0090 | Free | 70% |
The common result for a play doll labeled for ages three and older is 9503.00.0073. The invoice phrase “doll, whether or not dressed” does not establish the age-based suffix by itself.
Classification under the GRIs
GRI 1 places dolls and other toys in heading 9503. GRI 6 then applies the U.S. statistical structure. Statistical Note 1 to Chapter 95 requires classification by the youngest age for which the product is intended. Objective evidence includes size, small components, play pattern, packaging, warnings, instructions and marketing.
CBP ruling N209817 classified dressed dolls and related play components in 9503.00.0073 for children ages three through twelve. Current CBP practice likewise uses 9503.00.0073 for other supported children's toys in that age band. These rulings illustrate the analysis but do not replace examination of the entered model.
Products outside the stated conclusion
- Stuffed animals or fantasy creatures are still analyzed in heading 9503, but they are not described as human-form dolls.
- Doll garments, shoes, wigs or accessories imported separately require their own classification analysis.
- Retail mannequins and display models with a utilitarian display function may fall in heading 9618.
- Antique dolls over 100 years old may require Chapter 97 analysis.
- Electronic dolls, talking dolls and multi-article retail sets require review of their complete imported condition; batteries and radio features can add separate compliance duties.
Duties for China-origin dolls
For China-origin merchandise under 9503.00.00:
- Column 1 General duty is Free.
- The current legacy technology-transfer Section 301 dataset lists 9503.00.00 at 0% additional duty.
- The 2026 forced-labor Section 301 action adds 12.5% under 9903.05.31 because the provision is not in the reviewed U.S. Note 52(b) product-exception list.
- The former IEEPA reciprocal-duty program ended on February 20, 2026 and should not be added as a current duty line.
- No Section 232 or Section 201 safeguard was identified for this toy provision.
- No official AD/CVD order specifically covering generic human-form dolls was identified in the sources reviewed. An importer must still search the current scope by product, materials, origin, producer and exporter; an HTS number alone cannot exclude an order.
Formal entries are generally subject to the Merchandise Processing Fee at 0.3464%, subject to the applicable minimum and maximum. Commercial vessel cargo may also incur the 0.125% Harbor Maintenance Fee.
CPSC requirements for children's dolls
A doll designed or intended primarily for children 12 or younger is a children's product. Before importation and sale, the responsible manufacturer or importer should address:
- ASTM F963-23, incorporated by 16 CFR part 1250, including applicable mechanical, physical, flammability, chemical, stuffing and labeling provisions.
- Third-party testing by a CPSC-accepted laboratory and a Children's Product Certificate (CPC) based on passing results.
- CPSC certificate eFiling for covered imports beginning July 8, 2026.
- Total lead limits of 100 ppm in accessible substrates and 90 ppm in paint or similar surface coatings.
- The 0.1% limit for each regulated phthalate in accessible plasticized components of covered toys.
- 16 CFR part 1501 small-parts requirements for products intended for children under three, plus applicable choking-hazard warnings.
- Permanent tracking information on the product and packaging where practicable.
A dressed doll may contain multiple compliance materials: molded plastic, paint, synthetic hair, textile clothing, stuffing, metal fasteners, magnets and batteries. The bill of materials and testing plan should identify each accessible component and each production site.
Entry and documentation checklist
- Substantiate the youngest intended age and select 9503.00.0071, 9503.00.0073 or 9503.00.0090 accordingly.
- Establish origin under substantial-transformation principles and mark the article under 19 U.S.C. 1304 and 19 CFR part 134.
- Retain product drawings, photographs, packaging, age grading, instructions and component-level BOM.
- Prepare applicable ASTM F963, lead and phthalate reports, CPC, tracking-label data and eFiling information.
- Screen current Chapter 99 notes, forced-labor admissibility, sanctions and AD/CVD scope before entry.
Suggested commercial description
Human-form children's play doll, dressed, molded plastic body with textile clothing and synthetic hair, intended for ages 3 and older, model ..., country of origin ..., HTSUS 9503.00.0073.
Replace each ellipsis with actual model data. State “undressed” when appropriate. Separately imported clothing or accessories should not be described as a complete doll.
Official sources
- USITC current Harmonized Tariff Schedule
- CBP ruling N209817
- CPSC Toy Safety guidance
- CPSC ASTM F963 requirements
- CPSC Children's Product Certificate guidance
- USTR forced-labor Section 301 action
- ITA ACCESS AD/CVD search
Conclusion
A complete human-form play doll intended for children ages three through twelve is generally reported in 9503.00.0073, with a Free base duty. Use 9503.00.0071 for a substantiated under-three product and 9503.00.0090 only when the merchandise is not a children's product. China origin currently adds 12.5% under 9903.05.31 under the reviewed 2026 forced-labor Section 301 action. CPSC testing, CPC, eFiling, tracking and chemical limits remain separate mandatory compliance layers.
This publication is general information, not a binding CBP ruling or legal opinion. Final treatment depends on the entered product's age grading, materials, components, origin, producer and entry date.
Law and tariff reviewed through September 4, 2026.
2026 U.S. customs and import-law review
Legal review date: September 5, 2026. The USITC online HTSUS identified 2026 Revision 18 on this review date. Rates and Chapter 99 measures can change during the year, so the legally operative schedule is the edition in effect on the entry date.
1. Quick legal conclusion
The proposed reporting number is 9503000073 for Children's products intended for ages 3 to 12; representative play-doll code, but only for merchandise that matches this defined scope: A complete new human-form doll, dressed or undressed, principally designed as a children's plaything. This is a fact-dependent classification opinion, not a CBP ruling and not a determination of admissibility, origin or AD/CVD scope.
2. Facts that must be verified before entry
- Youngest intended age, packaging and warnings
- Body, coating, hair, clothing, stuffing and electronic materials
- Origin, model, factory and safety test reports
Also obtain the complete bill of materials, technical drawings, model numbers, operating manual, condition and configuration as imported, transaction chain, manufacturer/producer, country of origin of material inputs and intended U.S. use. A material difference requires a new analysis.
3. HTSUS analysis and controlling authority
- GRI 1 places dolls in heading 9503; the U.S. statistical suffix is then selected by the youngest supported intended age.
- Clothing worn by a complete doll does not change the classification, while separately imported doll clothes and accessories require separate treatment.
The analysis must begin with GRI 1, the heading text and binding Section/Chapter Notes, then proceed to GRI 2–5 only if legally necessary and to GRI 6 for subheadings. U.S. Additional Rules of Interpretation and Additional U.S. Notes are controlling where applicable. WCO Explanatory Notes are persuasive interpretive material but are not U.S. statutory text. A CROSS ruling is binding only for the requester and merchandise covered by its facts; materially similar rulings may be persuasive. CIT and Federal Circuit decisions control within their jurisdiction.
Goods outside this opinion include:
- Animal toys, separately imported clothing or parts, mannequins, antiques and products not supported as play dolls require separate classification.
For recurring or high-value entries, request a prospective binding ruling from CBP under 19 CFR Part 177 and disclose all material facts. A ruling request is not a substitute for checking post-ruling HTSUS amendments or trade remedies.
4. Duty, fee and tax matrix
| Charge | Legal treatment for this article |
|---|---|
| HTSUS Column 1 General duty | Apply the rate printed beside 9503000073 in the HTSUS edition effective on the entry date. Any rate stated elsewhere in the article remains provisional until that check is completed. |
| Merchandise Processing Fee (MPF) | Formal entries generally incur 0.3464% of entered value, excluding duty, freight and insurance, subject for FY 2026 to the CBP minimum $33.58 and maximum $651.50; an applicable preference program can alter MPF treatment. |
| Harbor Maintenance Fee (HMF) | 0.125% of value when commercial cargo is unloaded from a vessel at a covered U.S. port; it ordinarily does not apply to air freight. See 26 U.S.C. 4461–4462 and 19 CFR 24.24. |
| Section 301 / other Chapter 99 duty | Determine from the exact 8-digit HTSUS provision, country of origin, effective date and any valid exclusion. Report the required Chapter 99 number; do not assume the base HTS rate is the total landed duty. |
| Section 232 | Check current Chapter 99 notes, product/derivative coverage, origin and any required steel/aluminum/copper content, melt-and-pour or smelt-and-cast data. It does not apply merely because the article contains some metal. |
| AD duty | Not determinable from an HTS number. The written scope of an AD order is dispositive; HTS references are for convenience. Review product, producer/exporter, origin and circumvention findings. Cash-deposit and final assessment rates can differ. |
| CVD duty | The same written-scope rule applies. Confirm the case-specific company or all-others cash-deposit rate and liquidation instructions in Commerce ACCESS and ACE. |
| Safeguard / quota | Check current Chapter 99, quota and safeguard measures as of entry. Product scope, origin, quantity and quota period control. |
| Federal excise tax | No product-specific federal excise tax is identified from the stated facts; confirm the intended use and the current Internal Revenue Code before entry. |
| State sales/use and other state taxes | These are not CBP customs duties. They depend on destination, importer nexus, later sale/use and state/local law and require a separate domestic-tax review. |
This table does not calculate landed cost. The importer must also determine customs value under 19 U.S.C. 1401a, including assists, packing, royalties/license fees, proceeds and related-party acceptability. A “first sale” claim requires a bona fide sale for export to the United States, arm's-length evidence and a complete transaction trail.
5. AD/CVD and evasion review
Do not infer trade-remedy status from the HTS number alone. Screen the country of origin, producer and written scope of every active AD/CVD order, and test any applicable Chapter 99 provision as of the entry date.
The written scope description is dispositive; an HTSUS number in an order is only a convenience reference. If coverage is uncertain, obtain a Commerce scope ruling under 19 CFR 351.225 before relying on a non-covered position. Minor processing or assembly in a third country can trigger a circumvention analysis. False origin, undervaluation or evasion can lead to EAPA investigation under 19 U.S.C. 1517 and civil penalties under 19 U.S.C. 1592.
6. Partner Government Agency and product compliance
Children's dolls require a Children's Product Certificate supported by CPSC-accepted third-party testing. Review CPSIA lead/phthalate limits, ASTM F963/16 CFR Part 1250, small-parts, flammability, age grading, tracking labels and mandatory certificate eFiling for covered imports on or after July 8, 2026.
PGA admissibility is independent of tariff classification. Transmit all required agency data and documents through ACE; a CBP release does not cure a violation of an FDA, CPSC, EPA, FCC, DOT, USDA or other agency rule.
7. Origin, marking and UFLPA
Determine nonpreferential origin under the substantial-transformation test and any product-specific rule; do not rely only on the shipping country, invoice origin or location of final packing. Mark the article and, when required, its container under 19 U.S.C. 1304 and 19 CFR Part 134, unless a documented exception applies. Section 301, AD/CVD, government procurement and a preference program may use distinct origin rules.
Under 19 U.S.C. 1307 and the UFLPA, goods mined, produced or manufactured wholly or in part in Xinjiang, or by an entity on the UFLPA Entity List, are subject to a rebuttable presumption of exclusion. Maintain supplier identity, production, payment, logistics and input-tracing evidence; a generic supplier declaration is not enough for a high-risk supply chain.
8. Minimum entry file
- CBP entry/cargo release data and Form 7501 record, customs bond, commercial invoice, packing list and bill of lading/air waybill.
- Purchase orders, payment records, Incoterms, assists/royalties analysis and related-party or first-sale valuation support.
- Product specifications, drawings, photographs, manuals, composition/BOM, model cross-reference and condition as imported.
- Signed classification memorandum applying the GRIs, legal notes, current HTSUS text and relevant rulings, plus rejected alternatives.
- Origin and marking analysis; producer/supplier affidavits and traceability records; Chapter 99 and exclusion support.
- AD/CVD scope search, producer/exporter case numbers and cash-deposit instructions, even when the conclusion is “not covered.”
- All PGA registrations, certificates, laboratory reports, licenses, notices and ACE data required for this product.
Keep entry and supporting records for the statutory period, generally five years, under 19 U.S.C. 1508 and 19 CFR Part 163.
9. Principal legal risks
- Declaring a 10-digit number from the trade name without proving the imported condition and legally relevant characteristics.
- Omitting a Chapter 99 number or calculating only the Column 1 rate.
- Treating an AD/CVD HTS cross-reference as dispositive instead of reading the written scope.
- Using shipping country as origin without a substantial-transformation and marking analysis.
- Filing before PGA admissibility, certificates, laboratory evidence or supply-chain traceability are complete.
An incorrect entry can produce redelivery, exclusion/seizure, duty reassessment, interest, loss of liquidation defenses and penalties. If past entries contain a material error, promptly evaluate a post-summary correction, protest, prior disclosure under 19 CFR 162.74 or other corrective procedure with U.S. customs counsel; the correct route depends on entry and liquidation status.
10. Pre-entry action checklist
1. Lock the specifications and imported configuration for the exact SKU. 2. Re-run classification against the current HTSUS and record GRI/Note reasoning. 3. Determine customs value, nonpreferential origin and marking. 4. Screen Chapter 99, Section 301/232, quota/safeguard and every potentially relevant AD/CVD scope. 5. Complete the product-specific PGA review and obtain supporting certificates before shipment. 6. Calculate landed duties and fees, then have the importer and licensed customs broker validate ACE reporting. 7. For unresolved or commercially material classification issues, obtain a CBP Part 177 ruling before importation.
Official legal sources
- United States International Trade Commission; HTSUS 2026: Harmonized Tariff Schedule of the United States
- U.S. Customs and Border Protection; N209817: Dolls classified in 9503.00.0073
- Consumer Product Safety Commission; 16 CFR Part 1250: Toy Safety guidance
- USITC — Current Harmonized Tariff Schedule of the United States
- CBP — User fee table: MPF rate and FY 2026 minimum/maximum
- CBP — Harbor Maintenance Fee
- CBP — ACE: filing customs and Partner Government Agency data
- USTR — Section 301 tariff actions and exclusion search
- BIS — Section 232 steel and aluminum measures
- Commerce — AD/CVD FAQs, scope and circumvention rules
- Commerce — ACCESS AD/CVD proceeding search
- CBP — UFLPA rebuttable presumption
- CPSC — Certificates and mandatory eFiling guidance
- FDA — Importing food products into the United States
- EPA — TSCA requirements for importing chemicals
- PHMSA — Lithium battery transportation requirements
- FCC — Equipment authorization
- eCFR — 19 CFR Part 177: administrative rulings
- eCFR — 19 CFR Part 134: country-of-origin marking
- eCFR — 19 CFR Part 163: recordkeeping
> Legal notice: This article provides general U.S. customs and trade-compliance information based on the stated facts as of September 5, 2026. It is not a CBP, Commerce or PGA ruling and is not legal advice for a specific transaction. Current HTSUS/Chapter 99 text, agency requirements and case-specific AD/CVD instructions must be rechecked at entry.
Editorial note
Prepared by the Global HS Code Checker Editorial Team for customs-classification, tariff and import-policy research. The correct code and applicable measures may change with the merchandise's actual characteristics, jurisdiction, entry date and supporting record. Verify the current tariff, governing measures and competent customs authority before filing an entry. A reviewer is identified only after a named expert has completed the review.
