Ms. Frances Y. Wing
Toto USA, Inc.
7700 Spence Road
Fairburn, GA 30213

RE: The tariff classification of a plastic toilet seat with heating coil and remote control from Japan.

Dear Ms. Wing:

In your letter dated July 8, 2008, you requested a tariff classification ruling.

The submitted illustration depicts an item identified as a Washlet Model S300. This item is a toilet seat and lid made of plastic. This item is imported with mounting and connection hardware, so that it can be attached to a toilet bowl, which is not included in the importation. The toilet seat has an inner coil that stays heated according to the temperature that the consumer sets by a remote control, which is included in the importation. The remote control is designed to be installed on the wall next to the Washlet, rather than on the Washlet itself. It operates by means of a laser beam which it sends to the ceiling. The beam bounces off the ceiling and back to the Washlet.

This item includes five cleansing modes, using water from a toilet tank, which is not included in the importation. An adjustable wand, which extends from and retracts into the seat, allows the consumer to finely aim the washing spray. This item also includes an air dryer function. The temperature of the washing spray and the air dryer, the water and air flow rate and the adjustable wand are all set using the remote control.

Also located within the seat is an automatic air deodorizer. In between the seat and the lid is a hinge that is designed to ensure that the lid always closes silently. The lid opens automatically when an individual approaches it, based on a detection made by a sensor that is located in the lid. Likewise, the lid closes automatically when the sensor detects that the individual’s presence is no longer in close proximity. The Washlet includes a 3 ft power cord with a plug.

The Washlet and the remote control are considered to be “a set put up for retail sale,” within the meaning of General Rule of Interpretation (GRI) 3. Likewise, the toilet seat and lid, with all of its internal components, is considered to be a composite good, within the meaning of GRI 3. Even if the power cord was not connected to a power source, this item could still perform the primary function of a toilet seat and lid. The lid can be lifted and closed manually. Therefore, it is the opinion of this office that the toilet seat and lid provides this item with the essential character, within the meaning of GRI 3(b).

The applicable subheading for the Washlet Model S300 will be 3922.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for…seats and covers…of plastics: lavatory seats and covers. The rate of duty will be 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 on World Wide Web at

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 Specialist Gary Kalus at (646) 733-3055.


Robert B. Swierupski
National Commodity Specialist Division