Mr. David Prata
Mail Code 5055
Woonsocket, RI 02895
RE: The tariff classification of plastic dispenser bases from China
Dear Mr. Prata:
In your letter dated May 20, 2021, you requested a tariff classification ruling. Photographs, schematic diagrams, and a user’s manual was submitted along with your ruling request.
The products to be imported are identified as plastic dispenser bases, item numbers 608361 and 586685. You indicate that the plastic dispenser bases are components of a modular vitamin dispensing system. The countertop modular vitamin dispensing system is non-electrical and is hand-operated. This ruling request concerns only the plastic dispenser bases, which will be imported without the disposable plastic cartridges.
You state that the plastic dispenser bases are used with the disposable plastic cartridges. The consumer can purchase the base once and refill it with cartridges as needed, snapping the new cartridges in place in a similar manner as an inkjet printer cartridge. Each base dispenses one or more pills for easy access, and multiple bases can be interlocked for convenient storage.
Item number 608361 is a Single-Dispensing Base. All components are plastic except for a stainless steel ballast that counterweighs the pill catch. It measures approximately 4 5/8 inches high by 2 1/8 inches wide by 3 ¾ inches deep. This style dispenses one capsule when the consumer pulls open the door. The action of opening the door lifts a flipper beneath the refill cartridge, dropping a capsule down a spout and into the pill catch behind the door.
Item number 586684 is the Multi-Dispensing Base. All components are plastic except for a stainless steel ballast that counterweighs the pill catch. It measures approximately 4 5/8 inches high by 1 5/8 inches wide by 3 ¾ inches deep. This style dispenses multiple pills into a drawer from which the consumer can retrieve the appropriate dosage. A metering flap closes off the flow of pills when the drawer is opened, preventing overfilling and jamming.
You propose classification for the plastic dispenser bases in subheading 3924.90.5650, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Tableware, kitchenware, other household articles and hygienic or toilet articles, of plastics: Other: Other…Other.” However, the plastic dispenser bases which are part of the countertop modular vitamin dispensing system are intended for placement on a tabletop. The item is designed to hold and dispense vitamin and mineral tablets. As such, they qualify as tableware within the meaning of heading 3924, HTSUS, and are properly classified in subheading 3924.10.4000.
The applicable subheading for the plastic dispenser bases, item numbers 608361 and 588684 will be 3924.10.4000, HTSUS, which provides for “Tableware, kitchenware, other household articles and hygienic or toilet articles, of plastics: Tableware and kitchenware: Other.” The rate of duty will be 3.4 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 Dana L. Giammanco at [email protected]
Steven A. Mack
National Commodity Specialist Division