Mr. Charles T. Whitney
Native Times LLC, DBA Slopper Stopper
9295 Oak Hammock Lane
Jupiter, FL 33478

RE: The tariff classification of a stainless steel dog bowl and lid components from China.

Dear Mr. Whitney:

In your letter dated June 26, 2019, you requested a tariff classification ruling.

You have submitted photographs and detailed descriptions of components of a water bowl for dogs identified as the “Slopper Stopper.” The components include a silicone plug, a molded plastic lid, a silicone gasket and a stainless steel bowl, which will be imported separately.

Item 1 is described as a silicone plug. The purpose of the plug is to seal a hole in the plastic lid.  It is circular with a diameter of 2 inches.

Item 2 is described as a plastic dog bowl lid. It is a molded plastic lid with a diameter of approximately 9.84 inches and 2.5 inches thick.

The applicable subheading for the silicone plug and the plastic dog bowl lid will be 3923.50.0000, Harmonized Tariff Schedule of the United States, (HTSUS), which provides for articles for the conveyance and packing or goods, of plastics; stoppers, lids, caps and other closures, of plastics: stoppers, lids, caps and other closures. The rate of duty will be 5.3 percent ad valorem.

Item 3 is an item described as a silicone gasket seal. This gasket seal is a circular O-ring with the approximate diameter of 9.84 inches.

The applicable subheading for the silicon plastic O-rings will be 3926.90.4510, HTSUS, which provides for other articles of plastics and articles of other materials of headings 3901 to 3914: other: gaskets, washers and other seals: O-rings. The rate of duty will be 3.5 percent ad valorem.

Effective July 6, 2018, the Office of the United States Trade Representative (USTR) imposed an additional tariff on certain products of China classified in the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(b), HTSUS. The USTR imposed additional tariffs, effective August 23, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(d), HTSUS. Subsequently, the USTR imposed further tariffs, effective September 24, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(f) and U.S. Note 20(g), HTSUS. For additional information, please see the relevant Federal Register notices dated June 20, 2018 (83 F.R. 28710), August 16, 2018 (83 F.R. 40823), and September 21, 2018 (83 F.R. 47974). See also “Notice of Action and Request for Public Comment Concerning Proposed Determination of Action Pursuant to Section 301: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation” (June 20, 2018, 83 F.R. 28710). Products of China that are provided for in subheading 9903.88.01, 9903.88.02, 9903.88.03, or 9903.88.04 and classified in one of the subheadings enumerated in U.S. Note 20(b), U.S. Note 20(d), U.S. Note 20(f) or U.S. Note 20(g) to subchapter III shall continue to be subject to antidumping, countervailing, or other duties, fees and charges that apply to such products, as well as to those imposed by the aforementioned Chapter 99 subheadings.

Products of China classified under subheading 3923.50.0000 and 3926.90.4510, HTSUS, unless specifically excluded, are subject to the additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 3923.50.0000 and 3926.90.4510, HTSUS, listed above.

The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading.

Item 4 is identified as a circular stainless steel water bowl that measures approximately 9.84 inches in diameter by 4.19 inches deep.

The applicable subheading for the stainless steel dog bowl will be 7323.93.0080, HTSUS, which provides for table, kitchen or other household articles and parts thereof, of iron or steel…other, of stainless steel, other. The duty rate will be 2 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 the 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 items classified in 3923.50.0000, contact National Import Specialist Christina Allen at [email protected] or for items classified in 3926.90.4510 or 7323.93.0080, contact National Import Specialist Sandra Carlson at [email protected]


Steven A. Mack
National Commodity Specialist Division