OT:RR:CTF:VS H351125 AP
Jackson Ko, Vice President
Marketing Department
Whole Space Industries Co. Ltd.
400 West Main Street
Babylon, New York 11702
RE: PVC Cordless Mini Blinds; U.S. Content; 9903.01.34, HTSUS
Dear Mr. Ko:
This is in response to your July 30, 2025 ruling request, on behalf of Ever Ease
International Ltd. (“Ever Ease”), asking whether polyvinyl chloride (“PVC”) suspension resin
SE800 (“PVC resin”) used to make 1” light filtering PVC cordless mini blinds, 2” faux wood
PVC cordless mini blinds, and 3.5” room darkening vertical PVC cordless mini blinds
(collectively “mini blinds”) in Vietnam qualifies for the exemption under subheading
9903.01.34, Harmonized Tariff Schedule of the United States (“HTSUS”), and Chapter 99,
Subchapter III, U.S. Note 2(v)(xiii), HTSUS.
The requester has asked that certain information submitted in connection with this ruling
be treated as confidential. Inasmuch as this request conforms to the requirements of 19 C.F.R.
§ 177.2(b)(7), the request for confidentiality is approved. The information contained within
brackets in this ruling or in the attachments to the ruling request, forwarded to our office, will not
be released to the public and will be withheld from published versions of this ruling.
FACTS:
Ever Ease is a supplier of window coverings servicing customers in the United States. It
is a subsidiary of Whole Space Industries Ltd., which owns a factory in Vietnam. The factory in
Vietnam manufactures 1” light filtering PVC cordless mini blinds, 2” faux wood PVC cordless
mini blinds, and 3.5” room darkening vertical PVC cordless mini blinds in different sizes that
will be imported into the United States from Vietnam. All components of the mini blinds will be
made and assembled in Vietnam from PVC suspension resin SE800 manufactured in the United
States. The U.S. PVC resin will be compounded with other ingredients in Vietnam to make PVC
compound in the form of pellets. The pellets will be extruded into the mini blind components,
such as the slats. The PVC compound will consist of U.S. PVC resin, another material [X], and
other additives. The remaining percentage of the blinds includes other costs (i.e., ladder strings
and cords, packaging materials, labor costs, overhead). The requester has determined the U.S.-
made PVC content percentage of the mini blinds by multiplying the U.S. PVC resin portion of
the PVC compound by the percentage of PVC compound in the mini blind, which varies for each
mini blind depending on its type and size. The U.S. content is calculated by multiplying the
fixed U.S. made PVC percentage under the proprietary formula by the PVC compound
percentage. As an example of the contemplated transactions, the requester has provided the
following information for the blinds:
• 1” light filtering PVC cordless mini blinds
The requester arrived at the total price paid or payable for the 1” light filtering PVC
cordless mini blinds by adding the U.S. PVC content (34 percent), the cost of the [X] and other
additives ([X] percent), and the other costs for ladder strings and cords, packaging materials,
labor and overhead ([X] percent).
Size Others % PVC U.S. FOB $ U.S. PVC [X] and Other Others $
Compound % Made Content $ Additives $
PVC
%
23” x 64” [X]% [X]% 31% $[X] $[X] $[X] $[X]
27” x 64” [X]% [X]% 33% $[X] $[X] $[X] $[X]
29” x 64” [X]% [X]% 33% $[X] $[X] $[X] $[X]
31” x 64” [X]% [X]% 34% $[X] $[X] $[X] $[X]
34” x 64” [X]% [X]% 35% $[X] $[X] $[X] $[X]
35” x 64” [X]% [X]% 35% $[X] $[X] $[X] $[X]
36” x 64” [X]% [X]% 35% $[X] $[X] $[X] $[X]
39” x 64” [X]% [X]% 35% $[X] $[X] $[X] $[X]
Total: $[X] $[X] $[X] $[X]
(34%) ([X]%) ([X]%)
• 2” faux wood PVC cordless mini blinds
The requester arrived at the total price paid or payable for the 2” faux wood PVC cordless
mini blinds by adding the U.S. PVC content (29 percent), the cost of the [X] and other additives
([X] percent), and the other costs for ladder strings and cords, packaging materials, labor and
overhead ([X] percent).
Size Others % PVC U.S. FOB $ U.S. PVC [X] and Other Others $
Compound % Made Content $ Additives $
PVC
%
27” x 64” [X]% [X]% 29% $[X] $[X] $[X] $[X]
29” x 64” [X]% [X]% 29% $[X] $[X] $[X] $[X]
30” x 64” [X]% [X]% 29% $[X] $[X] $[X] $[X]
31” x 64” [X]% [X]% 29% $[X] $[X] $[X] $[X]
33” x 64” [X]% [X]% 29% $[X] $[X] $[X] $[X]
35” x 64” [X]% [X]% 30% $[X] $[X] $[X] $[X]
36” x 64” [X]% [X]% 30% $[X] $[X] $[X] $[X]
Total: $[X] $[X] $[X]
(29%) ([X]%) ([X]%)
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• 3.5” room darkening vertical PVC cordless mini blinds
The requester arrived at the total price paid or payable for the 3.5” room darkening
vertical PVC cordless mini blinds by adding the U.S. PVC content (31 percent), the cost of the
[X] and other additives ([X] percent), and the other costs for ladder strings and cords, packaging
materials, labor and overhead ([X] percent).
Size Others % PVC U.S. FOB $ U.S. PVC [X] and Other Others $
Compound % Made Content $ Additives $
PVC
%
42” x 63” [X]% [X]% 28% $[X] $[X] $[X] $[X]
54” x 63” [X]% [X]% 29% $[X] $[X] $[X] $[X]
66” x 63” [X]% [X]% 29% $[X] $[X] $[X] $[X]
78” x 63” [X]% [X]% 30% $[X] $[X] $[X] $[X]
66” x 84” [X]% [X]% 32% $[X] $[X] $[X] $[X]
78” x 84” [X]% [X]% 33% $[X] $[X] $[X] $[X]
90” x 84” [X]% [X]% 33% $[X] $[X] $[X] $[X]
104” x 84” [X]% [X]% 33% $[X] $[X] $[X] $[X]
Total: $[X] $[X] $[X] $[X]
(31%) ([X]%) ([X]%)
Furthermore, the exemplar information indicates that the factory in Vietnam purchased
[X] metric tons (“MT”) of U.S. PVC resin priced at $[X] per MT for a total price of $[X] from a
seller in Singapore who in turn purchased it from U.S. manufacturer [X] located in the United
States. Ever Ease submitted proof of payment. The port of loading was in the United States at
[X, X], and the place of delivery was Haiphong Port, Vietnam. The Incoterms were “CIF,
Haiphong, Vietnam.” The packing list reveals that [X] MT of PVC resin ([X] bags) produced by
the U.S. manufacturer [X] were shipped from the United States at [X, X] to Haiphong, Vietnam,
on June 28, 2025. According to the bill of lading, the shipper/exporter was the U.S.
manufacturer [X] and [X] bags of resin ([X] MT) departed from the United States at [X, X] to
Haiphong, Vietnam on June 28, 2025. The U.S. manufacturer issued a certificate of analysis
dated June 28, 2025, to the requester to verify the resin’s quality and compliance with specified
standards. The June 28, 2025 certificate of origin from the U.S. manufacturer’s forwarding agent
certifies that the exported [X] MT of resin manufactured in the United States are “products” of
the United States.
The total price paid or payable for the mini blinds on the invoices represents the customs
value. The commercial invoice from Ever Ease to the U.S. customer [X] for the 1” light filtering
PVC cordless mini blinds reveals that the light filtering mini blinds produced in Vietnam will be
shipped from Vietnam to the United States, and the Incoterms will be “FOB Haiphong,
Vietnam.” The U.S. customer will serve as the U.S. importer of record. The total price paid or
payable for [X] 1” light filtering PVC cordless mini blinds will be $[X]. The commercial
invoice from Ever Ease to the U.S. customer for the 2” faux wood PVC cordless mini blinds
reveals that the faux wood mini blinds produced in Vietnam will be shipped from Vietnam to the
United States, and the Incoterms will be “FOB Haiphong, Vietnam.” The total price paid or
payable for [X] 2” faux wood PVC cordless mini blinds will be $[X]. Ever Ease has not yet
issued an invoice to the U.S. customer for the 3.5” room darkening vertical PVC cordless mini
blinds. You advised that the total price paid or payable for the room darkening vertical mini
blinds will be $[X].
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ISSUE:
Whether the U.S.-origin PVC resin used to produce the 1” light filtering PVC cordless
mini blinds, the 2” faux wood PVC cordless mini blinds, and the 3.5” room darkening vertical
PVC cordless mini blinds qualifies for the U.S. content exemption under subheading 9903.01.34,
HTSUS.
LAW AND ANALYSIS:
Effective April 5, 2025, Presidential Executive Orders implemented “Reciprocal Tariffs.”
See Exec. Order No. 14257, 90 Fed. Reg. 15041 (Apr. 2, 2025); Exec. Order No. 14266, 90 Fed.
Reg. 15509 (Apr. 9, 2025); Exec. Order No. 14316, 90 Fed. Reg. 30823 (July 7, 2025); and
Exec. Order No. 14326, 90 Fed. Reg. 37963 (July 31, 2025). These additional tariffs apply to
imported goods of most countries, including Vietnam. All imported merchandise subject to
these Executive Orders must be reported with either the Chapter 99 provision under which the
reciprocal tariff applies or one of the Chapter 99 provisions covering exemptions to the
reciprocal tariffs.
As of the date of this ruling, imports from Vietnam are subject to additional duties under
subheading 9903.01.25, HTSUS, which states:
Articles the product of any country, except for products described in headings
9903.01.26–9903.01.33, 9903.02.02–9903.02.71, and 9903.96.01, and except as
provided for in headings 9903.01.34 and 9903.02.01, as provided for in subdivision
(v) of U.S. note 2 to this subchapter.
Subheading 9903.01.34, HTSUS, which is an exemption from the additional duties,
states:
The U.S. content of articles the product of any country, in which the U.S. content
of the article provides at least 20 percent of the Customs value of the imported
article, as provided for in subdivision (v)(xiii) of U.S. note 2 to this subchapter.
Chapter 99, Subchapter III, U.S. Note 2(v)(xiii), HTSUS, states:
The additional duties imposed by headings 9903.01.25, 9903.01.35, 9903.01.39,
9903.01.63, and 9903.02.01-9903.02.71 shall not apply to the U.S. content of an
article, provided at least 20% of the customs value, as determined under 19 U.S.C.
1401a, of the product is U.S. originating, consistent with heading 9903.01.34. For
greater certainty, with respect to an article for which at least 20% of the customs
value is U.S. originating, consistent with 9903.01.34, the additional duties imposed
by headings 9903.01.25, 9903.01.35, 9903.01.39, 9903.01.63, and 9903.02.01-
9903.02.71, shall apply only to the non-U.S. content of such article. Heading
9903.01.34 covers only the U.S. content portion of articles described by that
heading. The term “U.S. content” refers to the value of an article attributable to the
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components wholly obtained, produced entirely, or substantially transformed in the
United States.
Thus, “U.S. content” refers to the portion of an article’s customs value, determined under
19 U.S.C. § 1401a, attributable to components that are wholly obtained, entirely produced, or
substantially transformed in the United States. At least 20 percent of the total customs value
must be of U.S.-origin for the content to qualify under subheading 9903.01.34, HTSUS. This
exemption applies only to the U.S. portion. The remaining non-U.S. content remains subject to
duties under subheadings 9903.01.25, 9903.01.35, 9903.01.39, 9903.01.63, and 9903.02.01-
9903.02.71. See Chapter 99, Subchapter III, U.S. Note 2(v)(xiii), HTSUS.
Here, the certificate of origin and the certificate of analysis from the U.S. manufacturer
indicate that the resin was produced in the United States. Based on the invoices and bill of
materials, the U.S. content for the 1” light filtering PVC cordless mini blinds represents 34
percent of the total price paid or payable for the light filtering mini blinds. The U.S. content for
the 2” faux wood PVC cordless mini blinds is 29 percent of the total price paid or payable for the
faux wood mini blinds. The U.S. content for the 3.5” room darkening vertical PVC cordless
mini blinds is 31 percent of the price paid or payable for the darkening vertical mini blinds. The
U.S. content values for the 1” light filtering PVC cordless mini blinds ($[X]), the 2” faux wood
PVC cordless mini blinds ($[X]), and the 3.5” room darkening vertical PVC cordless mini blinds
($[X]) exceed 20 percent of the customs value and may be subtracted from the total price paid or
payable for the 1” light filtering PVC cordless mini blinds ($[X], the 2” faux wood PVC cordless
mini blinds $[X], and the 3.5” room darkening vertical PVC cordless mini blinds $[X].
Accordingly, only the remaining balance of the price paid or payable for the 1” light
filtering PVC cordless mini blinds (($[X], for the 2” faux wood PVC cordless mini blinds $[X],
and for the 3.5” room darkening vertical PVC cordless mini blinds $[X] will be subject to
additional duties pursuant to subheading 9903.01.34, HTSUS and Chapter 99, Subchapter III,
U.S. Note 2(v)(xiii), HTSUS.
HOLDING:
Based on the provided information, the PVC resin of U.S.-origin represents: (a) 34
percent of the customs value of the 1” light filtering PVC cordless mini blinds; (b) 29 percent of
the customs value of the 2” faux wood PVC cordless mini blinds; and (c) 31 percent of the
customs value of the 3.5” room darkening vertical PVC cordless mini blinds, which will be
imported from Vietnam, and the additional duties imposed by subheading 9903.01.25, HTSUS,
will not apply to the U.S. PVC resin consistent with subheading 9903.01.34, HTSUS, and
Chapter 99, Subchapter III, U.S. Note 2(v)(xiii), HTSUS.
This holding only applies to the specific facts presented. 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 U.S. Customs and Border Protection (“CBP”)] field office to
the transaction to which it is purported to relate is subject to the verification of the facts
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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.”
If it is subsequently determined that the information furnished is not complete and does
not comply with 19 C.F.R. § 177.9(b)(1), the ruling will be subject to modification or revocation.
If there is any change in the facts submitted to CBP, it is recommended that a new ruling request
be submitted in accordance with 19 C.F.R. § 177.2.
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,
Monika R. Brenner, Chief
Valuation and Special Programs Branch
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