Mr. Greg M. Johnson
Heath Tecna, Inc.
3225 Woburn Street
Bellingham, WA 98225

RE: The tariff classification of a plastic toilet seat and lid from Germany

Dear Mr. Johnson:

In your letter dated October 1, 2011, you requested a tariff classification ruling.

The submitted diagram depicts an item that is identified as a Seat Assembly – Toilet, part number A4 254 00467-704. This item is made of polycarbonate (PC) plastic material. The diagram reflects a drawing of a toilet seat with an attached lid and this assembly is labeled with the aforementioned part number. After importation, part number A4 254 00467-704 will be installed in a lavatory module of a civil aircraft.

In your ruling request you suggested classification of the Seat Assembly-Toilet in 8803.30.0060 Harmonized Tariff Schedule of the United States (HTSUS), as other parts of airplanes. You cited HRL 953562 to support your suggestion.

In ruling HRL 953562, the items under consideration were lavatory modules, which contained equipment and facilities for washing, drinking, dispensing of toilet articles, refuse disposal, emergency oxygen provisions, smoke detection, and other articles. The complete unit had a floor, ceiling, walls, and entrance door which are constructed of phenolic resin honeycomb sandwich panels. The lavatory modules were clearly identifiable as being suitable for use solely or principally with airplanes. They were not excluded by the terms of Note 2, Section XVII, HTSUS, because they were not among the listed products. Moreover, the lavatory modules were not parts and accessories covered more specifically by another heading in the Nomenclature. 

Classification of goods in the HTSUS is governed by the General Rules of Interpretation (GRIs).  GRI 1 states “... classification shall be determined according to the terms of the headings...”  GRI 3 states in pertinent parts (a) “The heading which provides the most specific description shall be preferred to headings providing a more general description.”

Section XVII General Explanatory Note (EN) (III) PARTS AND ACCESSORIES states that: “It should, however, be noted that these headings apply only to those parts or accessories which comply with all three of the following conditions: (a) They must not be excluded by the terms of Note 2 to this Section.... and (b) They must be suitable for use solely or principally with the articles of Chapters 86 to 88.... and (c) They must not be more specifically included elsewhere in the Nomenclature....

The Seat Assembly-Toilet is covered more specifically by another heading and therefore, classification under 8803.30.00 will not apply.

The applicable subheading for part number A4 254 00467-704 will be 3922.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for 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

You have also submitted diagrams of items identified as a Roller Assembly, part number C22101-165-009 and a Liner, part number RGS2425-101. Your inquiry does not provide enough information for a classification ruling on these items. The following is necessary:

Roller Assembly, part number C22101-165-009: Does the plastic run throughout the entire article or does it merely serve as an end cap? If the plastic runs throughout the roller, provide a breakdown of material components by value and weight. Describe the roller and how it functions in the lavatory. Explain how and where it is mounted.

Liner, part number RGS2425-101: Provide the metal composition of the liner. Provide a breakdown by weight if the liner is made of more than one type of metal. Provide a detailed description of its use and function. Explain how it mounts to the door.

When this information is available, you may wish to consider resubmission of your request. If you decide to resubmit your request, please include all of the material that we have returned to you, along with the information requested above.

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