When the recent tariffs were announced by the US, panic was the first reaction from tabletop roleplaying game publishers.
This was soon followed by a wave of hope as people shared an official exemption list which included "printed books, brochures, leaflets and similar printed matter in single sheets, whether or not folded" and "printed books, brochures, leaflets and similar printed matter, other than in single sheets" (see codes 49011000 and 49019900). Seemingly, TTRPG rulebooks might escape the tariffs!
However, ICv2 is reporting that this may not be the case. According to a pair of rulings dating all the way back to 1989 and 1991, TTRPG rulebooks are instead classified as "arcade, table or parlor games… parts and accessories thereof". These rulings came from the US Custom and Border Protection agency, and were applied to Columbia Games and West End Games, respectively.
The first ruling was titled "Fantasy Role Play Expansion Modules".
In our opinion, heading 9504 provides the more specific description of the merchandise in issue. The modules enhance fantasy game play; they were not designed for passive reading.
- US Customs and Border Protection, November 1989
The second ruling, titled "Fantasy role play games books are expansion modules are designed to enhance fantasy game play, not for passive reading" reads as follows.
As a result of the foregoing, the instant merchandise is classified under subheading 9504.90.9080, HTSUSA, as articles for arcade, table or parlor games, including pinball machines, bagatelle, billiards and special tables for casino games; automatic bowling alley equipment; parts and accessories thereof; other, other, other, other. The applicable rate of duty is 4.64 percent ad valorem.
- US Customs and Border Protection, November 1991
These rulings are both 35 years old, so there is no guarantee that the same ruling would be made today. This ruling, from last year, classifies a Shadowrun supplement as a book, noting that "This ruling only takes into consideration the books when imported separately." But it does cast doubt on the status of TTRPG rulebooks. Are they books or are they games, according to the US customs agencies? If the latter, TTRPG books coming from China would suffer the same 145% tariff that boxed sets, accessories, and boardgames do. That means that a $30K print run of a few thousand books would incur an additional $43,500 bill when arriving at port in the US--considerably more than it costs to manufacture them in the first place.
Products coming from countries other than China are currently subject to a lower 10% tariff. However, with the speed at which the situation changes, it is impossible for companies to plan shipments to the US. Whatever the tariffs, what is necessary for trade is stability. Most organisations need a lead time measured in weeks--or sometimes months--in order to budget and plan for manufacturing and international shipments, and the tariffs are currently changing on a daily basis. And without even knowing for sure whether TTRPG rulebooks incur the tariff, we may have to wait until the first shipment hits port to find out!
The Shipping Tariff Lottery #shorts
The gamble we face when deciding whether to ship product to the US right now. #Gaming #ShippingChallenges #Tariffs #Kickstarter #GameDesign
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