Alice Lin
Import Department
Intex Recreation Corp.
4001 Via Oro Avenue, Suite 210
Long Beach, CA 90810

RE: The tariff classification of spa accessories from China. Correction to Ruling Number N256431. Dear Ms. Lin:

This replaces Ruling Number N256431 dated September 11, 2014, which contained a clerical error. A complete corrected ruling follows.

In your letter dated August 18, 2014, you requested a tariff classification ruling. Illustrative literature was provided. No material breakdowns were provided.

Item #28500/E is the PureSpatm, spa cup holder. The item is a refreshment tray designed to securely attach to the spa wall. This item keeps beverages and snacks close by while one relaxes. Item #28501/E is a spa headrest. The item allows one to comfortably rest their head while relaxing in the spa. As depicted in the photo, the headrest appears to have an outer-covering of plastic. Additional information on the nature of the materials was provided, indicating that, this item is not fitted or stuffed with internal material, but rather is inflatable.

Item #28502E is the PureSpatm, spa seat. The item allows one to sit comfortably in the spa, while raising one’s height by means of two different height options. This seat is stated to be slip resistant.

Item #28507/E and item #28508/E are the PureSpatm, inflatable benches. The items are designed to fit around the spa and are made in the same color scheme as the spa. The items attach and lock into place with the spa. These benches are stated to be the perfect place to lounge and relax when sitting by the spa.

The applicable subheading for the spa headrest will be 3926.90.7500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Pneumatic mattresses and other inflatable articles, not elsewhere specified or included.” The rate of duty will be 4.2% ad valorem.

For the spa cup holder, spa seat and spa benches not enough product information was provided. Please provide descriptive literature and a catalog describing the spa type accessories, as well as a material breakdown for each accessory by composition (i.e., textiles {outer material and inside material}, plastics, etc.), weight of each material and cost of each material. Upon receipt of the additional information, this office will issue a binding ruling.

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 Neil H. Levy at E-mail address: [email protected].


Gwenn Klein Kirschner
National Commodity Specialist Division