The Product
- A plastic tubular body with a sponge applicator head, sold with a cap and one replacement sponge head.
- Twisting the device to the on position releases sunscreen; squeezing the body dispenses it onto the sponge.
- The clear body shows how much sunscreen is left.
- Imported and sold empty; the consumer fills it with their own sunscreen.
- Marketed solely as a sunscreen applicator, and to be registered with the FDA as a medical device.
CBP's Ruling
| Item | HTS code | CBP's description of the line |
|---|---|---|
| Boon Shmear Sunscreen Applicator, item B11561 | HTS 3926.90.9989 | [o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther |
Explanation
CBP found the applicator is an article of plastic, and no other heading describes it more specifically. Heading 3926 covers other articles of plastics, and CBP placed the applicator on the residual line for other articles under that heading.
The device is a plastic tube with a sponge head, imported empty for the user to fill with sunscreen.
The letter also notes. The letter notes the applicator may be subject to the Federal Food, Drug, and Cosmetic Act and the Bioterrorism Act, which the FDA administers.
Does this apply to your product?
It likely does if you can answer yes to each of these:
- Is it an applicator made of plastic with a tube body and a sponge head?
- Is it imported and sold empty, for the user to fill with sunscreen?
- Is it used and marketed only as a sunscreen applicator?
A no to any of them can mean a different code. A licensed broker can classify your product.
The code today
| HTS code | In today's schedule | Where it sits | Today's duty |
|---|---|---|---|
| 3926.90.9989 | ✓ Still in the schedule | Heading 3926 | Today's duty from China |
Checked against today's tariff schedule. The duty calculator opens with the code and country filled in.
Related rulings
Other rulings on plastic articles under heading 3926 include N325854 (a cellphone case), N328944 (a plastic pipette), N332780 (a plastic wheel), N333374 (a plastic bin) and N359131 (accessories).
- N359131March 6, 2026Accessories from China3926.90.9989, 6117.80.8730, 6212.90.0030
- N325854May 16, 2022Cellphone case from China3926.90.9985
- N328944November 8, 2022Plastic pipette from China3926.90.9985
- N332780May 19, 2023Plastic wheel from China3926.90.9985
- N325536May 5, 2022Plastic gasket from China3926.90.4590
- N332822May 31, 2023Three inflatable articles from China3926.90.7500
- N333374June 15, 2023Plastic bin from China3926.90.9985
- N336142November 15, 2023Plastic syringes from China3926.90.2100
Borderless, a licensed U.S. customs brokerage, summarized CBP ruling N341122 in plain English and checked its codes against the letter and today's tariff schedule. A ruling applies only to goods that match its facts; our terms explain the rest. Terms