OT:RR:CTF:CPMMA H337323 GIH
Mr. Dae Gill Jung
COWAY USA, Inc.
4221 Wilshire Blvd., Suite 210
Los Angeles, California 90010
RE: Affirmation of NY N307831; Classification of a toilet seat and electronic bidet
Dear Mr. Jung:
This letter is in response to your correspondence, dated January 17, 2024, with which you
request reconsideration of New York Ruling Letter (NY) N307831, dated December 9, 2019
(reconsideration request). In NY N307831, which was issued to Woongjin Coway USA, Inc.
(Coway) regarding the tariff classification of four models of electronic bidets under the
Harmonized Tariff Schedule of the United States (HTSUS), U.S. Customs and Border Protection
(CBP) classified the subject merchandise under subheading 3922.20.00, HTSUS, which provides
for “[b]aths, shower-baths, sinks, wash-basins, bidets, lavatory pans, seats and covers, flushing
cisterns and similar sanitary ware, of plastics: Lavatory seats and covers.” In your
reconsideration request, you assert that this classification is incorrect, and that the electronic
bidets are correctly classifiable under subheading 8424.89.90, HTSUS, which provides for
“[m]echanical appliances (whether or not hand-operated) for projecting, dispersing or spraying
liquids or powders; fire extinguishers, whether or not charged; spray guns and similar appliances;
steam or sand blasting machines and similar jet projecting machines; parts thereof: Other
appliances: Other.” Having reviewed NY N307831 and determined that it is correct, we hereby
affirm NY N307831 for the reasons set forth below.
The electronic bidets at issue were described in NY N307831, as follows:
Coway Premium Bidet Models BA-13E, BA-13R, BA-22E and BA22-R are toilet seats and lids
made of plastic. The E and R represent the shape of the seat. The seat has an inner coil that allows
the seat to be heated. It can be operated via remote control which is included. The incorporated
bidet has a stainless steel nozzle. It includes multiple cleansing modes as well as an air dryer
function.
Descriptions of the Coway Premium Bidet included in your reconsideration request are
consistent with those set forth above.
Classification under the HTSUS is in accordance with the General Rules of Interpretation
(GRIs). GRI 1 provides that the classification of goods will be determined according to the
terms of the headings of the tariff schedule and any relative section or chapter notes. In the event
that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal
notes do not otherwise require, the remaining GRIs 2 through 6 will then be applied in order.
GRI 1 makes it clear that “titles of Sections, Chapters and sub‑Chapters are provided for ease of
reference only; for legal purposes, classification shall be determined by the terms of the headings
and any relative Section or Chapter Notes.”
The Explanatory Notes (ENs), although neither dispositive nor legally binding, provide a
commentary on the scope of each heading of the HTSUS, and are the official interpretation of
the Harmonized System at the international level. See T.D. 89-80, 54 Fed. Reg. 35127, 35128
(Aug. 23, 1989).
Heading 3922, HTSUS, provides for “[b]aths, shower-baths, sinks, wash-basins, bidets,
lavatory pans, seats and covers, flushing cisterns and similar sanitary ware, of plastics.”
(emphasis added). The language of the heading specifically provides for toilet seats and covers
as well as bidets. However, the HTSUS does not provide a definition of the term “bidet;”
therefore, we construe such terms in accordance with their common commercial meanings,
ascertained by reference to “dictionaries, scientific authorities, other reliable information
sources,” “lexicographic and other materials,” and the pertinent ENs. C.J. Tower & Sons v.
United States, 673 F.2d 1268, 1271 (C.C.P.A. 1982); Simod America Corp. v. United States, 872
F.2d 1572, 1576 (Fed. Cir. 1989); GRK Can., Ltd. v. United States, 761 F.3d 1354, 1357 (Fed.
Cir. 2014). The Merriam-Webster Dictionary defines a “bidet” as: “a bathroom fixture used
especially for bathing the external genitals and the anal region” 1; and the online dictionary—
Dictionary.com—defines a bidet as: “a low, basin-like bathroom fixture that provides a water
stream for bathing the genital and anal areas, or a device attached to a standard toilet that
performs the same function.” 2 The ENs to heading 3922, HTSUS, do not provide a definition of
a bidet, but state that the heading:
covers fittings designed to be permanently fixed in place, in houses, etc., normally
by connection to the water or sewage systems. It also covers other sanitary ware
of similar dimensions and uses, such as portable bidets, baby baths and camping
toilets.
In Headquarters Ruling Letter (HQ) H320467, dated July 11, 2024, CBP classified a
mechanical bidet 3 designed to attach to a toilet under heading 3922, HTSUS. In that case, the
1
Bidet, Merriam-Webster, https://www.merriam-webster.com/dictionary/bidet (last visited March 6, 2026).
2
Bidet, Dictionary.com, https://www.dictionary.com/browse/bidet (last visited March 6, 2026).
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HQ H320467 was issued in response to a request for reconsideration of NY N319093, dated May 14, 2021, which
described the product at issue as follows: “The Bio Bidet is a self cleaning [sic] nonelectric dual nozzle mechanical
bidet. The hand operated bidet can easily attach to any toilet. It is made of plastic and metal materials. Once
attached, the operator must turn on the water supply so that water flows both to the toilet tank and the bidet
attachment. There are two nozzles for controlling front and back wash and multiple water pressure applications.”
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bidet did not incorporate a toilet bowl, seat, or cover, and was installed between the purchaser’s
toilet bowl and seat. It further connected to the water line to provide water flow. CBP found
that the “definition of a bidet is not contingent upon whether the product itself contains a toilet or
a toilet seat; rather, the bidet can be designed to attach to a toilet, as long as the bidet is fixed in
place to the toilet.” CBP further concluded that bidets are typically connected to a dwelling’s
water line and are distinct in form and function from the personal cleaning devices classified in
8424, HTSUS, that include separate refillable water reservoirs and do not connect to a dwelling’s
water line. See e.g., NY 859160, dated January 16, 1991; NY D836693, dated November 16,
1998; and NY N295685, dated April 25, 2018.
The subject merchandise in this case serves two purposes: to provide a standard seat and
cover on the toilet bowl and, when uncovered, to provide the user with the ability to bathe the
external genitals and the anal region. The mechanism designed to bathe the user is attached to
the toilet seat and the toilet bowl and uses water from a dwelling’s water line to provide a water
stream, satisfying the definition of a “bidet.” Here, we find that the Coway Premium Bidets are
comprised of the toilet seat, cover, and bidet which are attached together to form an inseparable
whole. Under GRI 1, we find the Coway Premium Bidets are classifiable under heading 3922,
HTSUS, as its components, “bidets” and “seats and covers,” are provided for eo nomine in this
heading.
In your request for reconsideration, you argue that the subject merchandise is classified in
heading 8424, HTSUS. You state that the Coway Premium Bidet is “not permanently or directly
connected to the plumbing line,” and that the subject merchandise is “identical to that of portable
electric bidets, the device holding 200 milliliters of water operated by battery…[.]” As discussed
in HQ H320467, supra, personal cleaning devices with separate re-fillable water reservoirs that
do not connect to a dwelling’s water line have been previously classified in heading 8424,
HTSUS. However, based on the information provided, the Coway Premium Bidet is bolted to
the toilet fixture and attaches to a water line to provide water; it is not equipped with a separate
re-fillable water reservoir like those in the described personal cleaning devices, above. The tank
mentioned in your request is used to heat water prior to spraying; the water line distributes water
to the tank, where it is heated and then dispensed in the toilet. The water itself comes from the
dwelling’s water line, not from the user re-filling the tank manually. Additionally, the sprayer is
not handheld, but instead projects directly from the toilet. The mechanisms of the Coway
Premium Bidet satisfy the definition of a bidet, and therefore on its own would be classified in
heading 3922, HTSUS, and not in heading 8424, HTSUS.
In considering the six-digit HTSUS classification, under GRIs 1 and 6, we find that the
toilet seat and cover provide the basic purpose of the subject merchandise. In the absence of all
other functions, the Coway Premium Bidet is continually used as a toilet seat and cover. The
toilet seat is permanently attached to the toilet bowl and its function as a seat is required during
each use, whether simply toileting or when using the bidet. Neither the spraying nor heating
capabilities of the bidet are required for each use. When seated, the user could opt not to use the
spraying function but would still need to sit on the toilet seat. Therefore, the Coway Premium
Bidets are classified in heading 3922.20, HTSUS, as toilet seats and covers.
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For the aforementioned reasons, we hereby affirm NY N307831. Accordingly, by
application of GRIs 1 and 6, the subject Coway Premium Bidet is properly classified in heading
3922, HTSUS, as a toilet seat and cover, and is specifically classified in subheading 3922.20.00,
HTSUS, which provides for “Baths, shower-baths, sinks, wash-basins, bidets, lavatory pans,
seats and covers, flushing cisterns and similar sanitary ware, of plastics: lavatory seats and
covers.” The column 1, general rate of duty is 6.3 percent ad valorem.
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 online at:
https://hts.usitc.gov.
Sincerely,
Yuliya A. Gulis, Director
Commercial and Trade Facilitation Division
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