CLA-2-39:OT:RR:NC:N1:137
Patrick Kim
FNS Customs Brokers, Inc.
1545 Francisco St.
Torrance, CA 90501
RE: The tariff classification of electronic bidets from South Korea
Dear Mr. Kim:
In your letter dated November 21, 2019, you requested a tariff classification ruling on behalf of your client Woongjin Coway USA, Inc.
Coway Premium Bidet Models BA-13E, BA-13R, BA-22E and BA22-R are toilet seats and lids made of plastic. The E and R represent the shape of the seat. The seat has an inner coil that allows the seat to be heated. It can be operated via remote control which is included. The incorporated bidet has a stainless steel nozzle. It includes multiple cleansing modes as well as an air dryer function.
The toilet seat/bidet and 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/bidet and lid, with all of its internal components, is considered to be a composite good, within the meaning of GRI 3. Even without all the other functions, this item could still perform the primary function of a toilet seat/bidet 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 Coway Premium Bidet Models BA-13E, BA-13R, BA-22E and BA-22R will be 3922.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Baths, shower baths, sinks, washbasins, bidets, lavatory pans, seats and covers, flushing cisterns and similar sanitary ware, of plastics: Lavatory seats and covers. The general 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 the 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 Specialist Christina Allen at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division