OT:RR:CTF:VS H345037 ACH
Mr. Jeremy Pisiano
FWC2026 US, Inc.
396 Alhambra Circle
Coral Gables, FL 33134
RE: Subheading 9817.60.00, HTSUS; Equipment and Goods related to FIFA Club World Cup
2025™ and FIFA World Cup 26™
Dear Mr. Pisano:
This is in response to your ruling request, dated February, 6, 2025, on behalf of FWC2026
US, Inc., its parent company the Fédération Internationale de Football Association and its
subsidiaries and affiliates, and all entities and individuals acting on their behalf (together,
“FIFA”), as it relates to the organization of and participation in the events described below,
concerning the eligibility for duty-free treatment under subheading 9817.60.00, Harmonized
Tariff Schedule of the United States (“HTSUS”), of certain equipment and goods related to the
preparation, operation, and competition of the FIFA Club World Cup 2025™ to be held in the
United States in 2025 and the FIFA World Cup 26™ (together, “World Cups”) to be held in the
United States, Canada, and Mexico.
FACTS:
FIFA is an association organized under Swiss law that was founded “to govern football
and develop the game around the world.” As the global governing body for football or soccer, as
it is more commonly known in the United States (henceforth to be referred to as “soccer”), FIFA
oversees all facets of the game from promoting the development of soccer at every level—
grassroot initiatives to elite international competitions—to setting the rules of the game and
ensuring their consistent application. FIFA also works to advance the sport through innovation,
education, and collaboration with its over 200 member associations representing virtually every
country in the world. FIFA’s vision is to make the game of soccer truly global. FIFA organizes
tournaments such as the FIFA World Cup™, FIFA Women’s World Cup™ and the FIFA Club
World Cup™.
FIFA is scheduled to host/co-host two of its iconic competitions in the United States
during the next two years. These events are expected to draw over 1.5 billion global viewers and
millions of visitors and attendees to the United States and will require substantial operational
activity. These tournaments will take place over an extended period and will have a substantial
footprint across the United States as follows:
FIFA Club World Cup 2025™
The inaugural FIFA Club World Cup 2025™, the premier global club competition in
men’s soccer, is scheduled to be played in the United States from June 15 to July 13, 2025, across
12 venues in 11 different cities. The FIFA Club World Cup 2025™ competition will bring the
top 32 clubs together from around the world, representing the six continental confederations.
These 32 clubs will compete and after 63 matches, one club will emerge as the Club World Cup
champion.
Preparations for the FIFA Club World Cup 2025™ are well on their way and will require
the substantial importation and exportation of goods to ensure that not only FIFA is well placed
to put on this international sporting event, but that teams and players also have the necessary
equipment and tools to perform their best.
FIFA World Cup 26™
The FIFA World Cup 26™ is the most prestigious competition in men’s soccer and is one
of the most watched sporting events in the world. During the most recent World Cup hosted by
Qatar in 2022, over 1.5 billion people watched, and FIFA expects an even larger audience for the
FIFA World Cup 26™ that, for the first time, will be held across three countries, the United
States, Canada, and Mexico. In addition, the FIFA World Cup 26™ will host an expanded
number of national teams, up from 32 to 48. This will entail more matches than ever before,
with 78 of those 104 matches taking place in the United States and culminating with the final in
New Jersey and New York.
From June 11, 2026, through July 19, 2026, the FIFA World Cup 26™ will be played in
16 venues across North America, including 11 venues in the United States: Arlington, Texas;
Atlanta, Georgia; East Rutherford, New Jersey; Foxborough, Massachusetts; Houston, Texas;
Inglewood, California; Kansas City, Missouri; Miami Gardens, Florida; Philadelphia,
Pennsylvania; Santa Clara, California; and Seattle, Washington. As part of hosting these
matches, FIFA will need to support the movement of goods across match sites for the
preparation, operations, and deployment of the tournament.
In your ruling request, you indicate that the following “tournament equipment and goods”
will be imported into the United States for the World Cups:
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• Personal items for FIFA Client Groups;
• Food and beverages for personal use by FIFA Client Groups;
• Alcoholic beverages for personal use by FIFA Client Groups;
• Tobacco products for personal use by FIFA Client Groups;
• Sports equipment for tournament use;
• Referee equipment for tournament use;
• Team training equipment for use by teams for training for tournament;
• Infrastructure equipment/temporary infrastructure equipment & equivalent for
tournament and event use;
• Special events goods/stage equipment/venue equipment & equivalent for tournament and
event use;
• Pitch/field management equipment to support and maintain practice and match fields;
• Uniforms for team and all FIFA tournament and event use;
• Furniture & office equipment & equivalent for staging tournament and events;
• Catering equipment for staging tournament and events;
• Anti-doping samples collection & equipment to ensure compliance with international
regulations for the tournament;
• Medical equipment to be used by FIFA Client Groups for tournament use;
• Broadcast, audio & media equipment to be used by accredited media and the like to be
used for tournament and events;
• Technology equipment to be used by FIFA Client Groups for staging and production of
tournament and events;
• Vehicle & transport equipment for use in tournament and events;
• Promotional materials for promotion and use in tournament and events;
• Commercial affiliate and partner/sponsor goods for staging and production for
tournament and events;
• Hospitality items for displaying the culture of their country, team, sport or bid for future
events for use in tournament and events; and,
• Participant member of association goods - personal items of teams for tournament and
event use for execution of the games.
In a meeting between U.S. Customs and Border Protection (“CBP”) and FIFA on
February 28, 2025, FIFA stated that these items are not intended for sale or distribution to the
public. FIFA explained that the food, beverage, alcohol, and tobacco will be used by FIFA and
its client groups to provide comfort and luxury for the visiting teams and client groups.
FIFA included a description of the intended principal use of the tournament equipment
and goods as part of the description and provided that the importation of the equipment and
goods for use in tournament and/or events, collectively the “events,” fell within the scope of “an
international athletic event” and was covered under subheading 9817.60.00, HTSUS. The
following are referred to as “events” by FIFA:
• The FIFA congress, opening, closing, award and other ceremonies, the preliminary draw,
the final draw and any other draws, any mascot launch and other launch activities;
• Any seminars, meetings, conferences, workshops, and press conferences;
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• Any official public viewing or other fan-related events;
• Any cultural activities, in particular concerts, exhibitions, displays, shows or other
expression of cultures;
• Any events, activities, projects and/or programs for social and human development as
well as environmental protection, other corporate social responsibility, humanitarian, or
similar charity projects;
• Any football matches and training sessions; and,
• Any other activity that FIFA considers relevant for the staging, organization, preparation,
marketing, promotion or winding-up of the Competitions.
FIFA is seeking to confirm the applicability of subheading 9817.60.00, HTSUS, to the
“tournament equipment and goods” enumerated above and imported into the United States by
FWC2026 US, Inc., FIFA, its subsidiaries and affiliates, as well as by FIFA Client Groups.
ISSUE:
Whether the various equipment and goods related to the preparation, operation, and
competition of FIFA Club World Cup 2025™ and FIFA World Cup 26™ are eligible for dutyfree
treatment under subheading 9817.60.00, HTSUS, and whether donating the equipment and goods
after the conclusion of the events for legacy purposes to be permanently integrated into the
venue/stadium use and/or donated to the public would be acceptable under this subheading.
LAW AND ANALYSIS:
Subheading 9817.60.00, HTSUS, provides duty-free treatment for:
Any of the following articles not intended for sale or distribution to the public:
personal effects of aliens who are participants in, officials of, or accredited
members of delegations to, an international athletic event held in the United
States, such as the Olympics and Paralympics, the Goodwill Games, the Special
Olympics World Games, the World Cup Soccer Games, or any similar
international athletic event as the Secretary of the Treasury may determine, and of
persons who are immediate family members of or servants to any of the foregoing
persons; equipment and materials imported in connection with any such foregoing
event by or on behalf of the foregoing persons or the organizing committee of
such an event, articles to be used in exhibitions depicting the culture of a country
participating in such an event; and, if consistent with the foregoing, such other
articles as the Secretary of the Treasury may allow.
Subheading 9817.60.00, HTSUS, was added to the HTSUS with the enactment of the
Miscellaneous Trade and Technical Corrections Act of 2000, Public Law 106-476 (November 9,
2000). The Senate Report stated with regard to this new provision:
This provision would amend subchapter XVII of chapter 98 of the HTS by
inserting a new heading 9817.60.00 for duty free treatment of the personal effects
of participants in, officials of, and accredited members of delegations to,
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international athletic events, including the paralympics, held in the United States
provided that these items are not intended for sale or distribution in the United
States. H.R. 2715 would also exempt the articles covered under this provision
from taxes and fees and would give the Secretary of the Treasury discretion to
determine which athletic events, articles, and persons are covered under this
provision.
See S. Rep. No. 503, 106th Cong., 2nd Sess. (2000) (“Tariff Suspension and Trade Act of
2000”). The House Report contains virtually identical language with regard to the provision.
See H.R. Rep. No. 789, 106th Cong, 2nd Sess. (2000) (“Miscellaneous Trade and Technical
Corrections Act of 2000”).
In explaining the reason for the creation of subheading 9817.60.00, both the House and
Senate Reports stated:
The Committee recognizes the importance of international athletic events and the
tremendous efforts of the athletes and participants. Although athletes and other
officials connected with certain sporting events are currently afforded duty free
treatment for their personal belongings and equipment under current law, such
treatment will expire in December 2002. This legislation will give athletes and
participants of future competitions certainty regarding their future duty liability.
See S. Rep. No. 503, 106th Cong., 2nd Sess. (2000), and S. Rep. No. 503, 106th Cong., 2nd Sess.
(2000).
The World Cup Soccer Games are specifically enumerated under subheading 9817.60.00,
HTSUS, as eligible international athletic events and therefore, this requirement under subheading
9817.60.00, HTSUS, is met. Moreover, you state that the items are not intended for sale or
distribution to the public. Instead, according to the information provided, distribution of the
imported merchandise will be limited to participants and tournament organizers, including the
FIFA Client Groups. We are therefore satisfied that the merchandise constitutes “articles not
intended for sale or distribution to the public” for purposes of 9817.60.00, HTSUS.
Accordingly, the last issue is whether the merchandise constitutes “equipment and
materials imported in connection with any such foregoing event by or on behalf of the foregoing
persons or the organizing committee of such an event . . .”. Based on the information you
provided, some of the requested items fall within the purview of subheading 9817.60.00,
HTSUS, as they have already been approved as being “in connection with” an international
athletic event in previous rulings issued by CBP. In New York Ruling Letter (“NY”) N273612,
CBP determined that the following personal effects, and necessary and support equipment related
to the 2016 Centennial Copa America, falls within the purview of subheading 9817.60.00,
HTSUS:
• Soccer goals, nets, balls, stadium seating, food for the team/family, display racks
• Audio/media equipment
• Uniforms/banners/pictures
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• Furniture/Office equipment
• Promotional materials tied to the event
• Timing equipment
• Venue equipment and materials to run the event, such as whistles, stretchers
• Medical/Training materials such as bandages
• Sponsors’ goods, materials and equipment to run the event
• Team training materials, equipment, tools, uniforms or accessories that are required for
use or to be used to execute the games
• Hospitality items that assist an accredited member in displaying the culture of their
country, team, sport or bid for future hosting of the event
• Broadcasters and Media accredited parties’ material, equipment and goods needed or
used in conjunction with the event
• Personal items of the accredited family members
Moreover, CBP has previously held that “team tents, comforts, and the like” qualify as
being “in connection with” international athletic events. See NY N237173, dated January 18.
2013; NY N239161, dated March 21, 2013; NY N240047, dated April 22, 2013; NY N242515,
dated June 21, 2013; NY N242860, dated June 26, 2013; NY N246130, dated October 25, 2013;
NY N247123, dated November 20, 2013; and NY N233829, dated October 23, 2012.
CBP must also determine whether the additional requested goods, such as food, alcohol,
and tobacco products, are imported “in connection with” the World Cups. In Mont v. United
States, 587 U.S. 514 (2019), the Supreme Court wrote: “The Court has often recognized that “in
connection with” can bear a “broad interpretation.” Merrill Lynch, Pierce, Fenner & Smith Inc.
v. Dabit, 547 U. S. 71, 85, 126 S. Ct. 1503, 164 L. Ed. 2d 179 (2006) (interpreting “in connection
with the purchase or sale” broadly in the context of §10(b) of the Securities Exchange Act of
1934, 15 U.S.C. §78j(b)); see, e.g., United States v. American Union Transport, Inc., 327 U. S.
437, 443, 66 S. Ct. 644, 90 L. Ed. 772 (1946) (describing the phrase “in connection with” in the
Shipping Act, 1916, 39 Stat. 728, as “broad and general”). The Court has also recognized that
“‘in connection with’ is essentially indeterminate because connections, like relations, stop
nowhere.” Maracich v. Spears, 570 U. S. 48, 59, 133 S. Ct. 2191, 186 L. Ed. 2d 275 (2013)
(quotation altered).”
Accordingly, the term “in connection with” has been interpreted by the courts to be quite
broad, and CBP has previously allowed articles imported as “comforts” to enter under
subheading 9817.60.00, HTSUS. Thus, the additional goods listed by FIFA will also be eligible
for duty-free treatment, as it will allow the participants and facilitators to have access to personal
comforts. Since these products are “comforts” to be used only by FIFA Client Groups for
personal use and not for sale or distribution to the public, fans, or attendees, they will also qualify
as imported “in connection with” the World Cups.
Furthermore, in determining whether goods imported by FIFA, FWC2026 US, Inc., its
subsidiaries and affiliates, as well as by FIFA Client Groups are imported “on behalf of the
foregoing persons or the organizing committee”, CBP has looked to agreements made with such
people or organizations. In NY N261136, dated February 13, 2015, CBP addressed whether a
company importing bleacher equipment for a Formula One race in Austin could receive duty-free
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treatment under 9817.60.00, HTSUS. CBP stated, “[a]llowance for duty-free treatment under
9817.60.00 should be granted, upon your client submitting satisfactory evidence by means of a
rental or lease agreement or a similar use agreement issued to an accredited member (organizing
committee) or authority, i.e., Circuit of the Americas [the venue], or the FIA [the hosting
committee], disclosing that the disassembled event seating will be used at the Formula 1, United
States, Grand Prix, at Austin.” Therefore, to support whether an organization is importing
articles “on behalf of the foregoing persons or organizing committee,” an organization must be
able to show some agreement with the foregoing persons or organizing committee, such as FIFA
or the venues hosting the World Cups.
Based on the information you provided, we find that the merchandise at issue falls within
the coverage of heading 9817.60.00, HTSUS, and qualifies for duty-free entry in that provision,
provided that none of the items is being offered for sale or distribution to the public, and
provided that said items are imported by, or on behalf, of eligible individuals or entities as
discussed above. With regard to items that you have not specifically identified, it is within the
discretion of the port to determine whether the items meet the conditions and requirements of
subheading 9817.60.00, HTSUS. We recommend that you work with the port of entry with
regard to any items not identified herein and any other issues you may have, such as the correct
marking of the items, prior to importation.
We note however, that in accordance with U.S. Note 8, Subchapter XVII, Chapter 98:
“[a]ny article exempt from duty under heading 9817.60.00 shall be free of taxes and fees that
may otherwise be applicable, but shall not be free or otherwise exempt or excluded from routine
or other inspections as may be required by the Customs Service.”
Finally, FIFA has also inquired as to whether donating goods for legacy purposes after the
event to non-profit organizations or other charity or public entities would be considered
distribution and negate the duty-free status available under subheading 9817.60.00, HTSUS.
FIFA states that the association could include provisions in the agreements with these donee
organizations to ensure that donated items cannot be redistributed, resold, or auctioned. We
agree.
In NY N335930, dated November 1, 2003, CBP held that goods distributed to
participants, games officials, and volunteers could still fall under subheading 9817.60.00,
HTSUS, because they were not intended for distribution to the public. Therefore, there is
precedent for limited distribution to those directly related to the games being allowed under this
subheading. In addition, FIFA is seeking to distribute these goods to specific organizations, not
to the public at large. Therefore, FIFA’s intended donations would not violate this provision of
subheading 9817.60.00, HTSUS, as long as there are assurances provided that the goods will not
later be sold or distributed to the public.
HOLDING:
The equipment and goods related to the preparation, operation, and competition of FIFA
Club World Cup 2025™ and FIFA World Cup 26™ at issue are eligible for duty-free treatment
under subheading 9817.60.00, HTSUS.
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Please note that 19 C.F.R. § 177.9(b)(1) provides that “[e]ach ruling letter is issued on the
assumption that all of the information furnished in connection with the ruling request and
incorporated in the ruling letter, either directly, by reference, or by implication, is accurate and
complete in every material respect. The application of a ruling letter by a Customs Service field
office to the transaction to which it is purported to relate is subject to the verification of the facts
incorporated in the ruling letter, a comparison of the transaction described therein to the actual
transaction, and the satisfaction of any conditions on which the ruling was based.”
A copy of this ruling letter should be attached to the entry documents filed at the time this
merchandise is entered. If the documents have been filed without a copy, this ruling should be
brought to the attention of the CBP officer handling the transaction.
Sincerely,
Yuliya A. Gulis, Director
Commercial and Trade Facilitation Division
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