Amanda Levitt
Sandler, Travis & Rosenberg, P.A.
675 Third Avenue, Suite 1805-06
New York, New York 10017

RE: The tariff classification of plastic child toilet seats from China

Dear Ms. Levitt:

In your letter dated May 20, 2021 you requested a tariff classification ruling on behalf of your client, Jool Products, LLC.

The first item under consideration is referred to as Potty Chair (Item No. P-Chair). The Potty Chair consists of a portable toilet seat, composed entirely of plastic components, intended for use by children. It includes a hollow plastic base shaped like a toilet bowl onto which the user will sit. There is also a separate plastic pan that slides in and out of the base to allow for easy cleanup. Finally, there is a plastic back to provide support to the child when the Potty Chair is in use. The sole use of the Potty chair is as a portable toilet.

The second item under consideration is referred to as Real Feel Potty (Item No. RFeel-A). The Real Feel Potty is composed entirely of plastic. It is designed to emulate a real toilet. It has a plastic base shaped like a toilet. There is also a separate plastic pan that will slide in and out of the base for cleaning. This toilet includes a removable plastic cover that is shaped like a toilet seat and can be used independent of the base on a regular toilet once the toddler is old enough to sit on a regular toilet. To enhance the realistic aspect of this toilet, there is also a handle that can be pulled down to make a flush sound. The sole use of the Real Feel Potty is as a portable toilet.

The applicable subheading for the portable toilet seats 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. The general rate of duty will be 6.3 percent ad valorem.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 3922.20.0000, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty.  At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 3922.20.0000, HTSUS, listed above.

The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading.  For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at and, respectively.

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 ruling, contact National Import Specialist Christina Allen at [email protected].


Steven A. Mack
National Commodity Specialist Division