CLA-2-95:OT:RR:NC:N4:424

Ms. Autumn Oliver
Lifetime Products
P.O. Box 160010
Clearfield, UT 84016

RE: The tariff classification of paddleboard padding from China

Dear Ms. Oliver:

In your letter dated January 16, 2020, you requested a tariff classification ruling. Photographs and a description of the paddleboard padding, part number 1203641, was received with your inquiry.

The product at issue is described as an EVA foam pad with a diamond cut texture pattern that contains an adhesive backing which is applied in China. You state that the product is pre-measured and cut to fit a particular stand-up paddleboard. The padding serves as a cushion for the stand-up paddler. The item is designed to be used in the sport of paddle boarding.

The applicable subheading for the paddleboard padding will be 9506.29.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Articles and equipment for general physical exercise, gymnastics, athletics, other sports…parts and accessories thereof: Water skis, surf boards, sailboards and other water-sport equipment; parts and accessories thereof: Other…Other.” The rate of duty will be Free.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9506.29.0080, HTSUS, unless specifically excluded, are subject to an additional 15 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 9506.29.0080, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china respectively.

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 on World Wide Web at https://hts.usitc.gov/current.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Roseanne Murphy at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division