Jimmy Nie
Primy Corporation Ltd.
220 Dexiang Road
Pinghsa, Zhuhai 519055

RE: Classification of an aluminum vanity with sink made in China

Dear Mr. Nie:

This is in reply to your letter dated September 2, 2021, requesting a tariff classification ruling for an aluminum vanity with sink. In lieu of samples, illustrative literature and product descriptions were provided.

As described in the provided literature, the subject merchandise, model no. USAV01, is a composite good consisting of an aluminum vanity cabinet and a vitreous ceramic sink with pre-drilled faucet and drain holes. The vanity measures 23.6" (W) x 19.7" (D) x 34.7" (H). It is used to wash and provide storage in a bathroom or powder room and is made in China. See images below:

Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is made in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes (together known as legal notes). If the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 are then applied in order.

Because the subject article is composed of different materials (aluminum and ceramic), it is considered a composite good for tariff purposes. The Explanatory Notes to the HTSUS, GRI 3(b) (VIII) state that “the factor which determines essential character will vary between different kinds of goods. It may, for example, be determined by the nature of the materials or components, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the goods.” When the essential character of a composite good can be determined, the whole product is classified as if it consisted only of the material or component that imparts the essential character to the composite good.

This office finds that the essential character of the subject article is imparted by the aluminum cabinet.

The applicable classification for the aluminum vanity with sink, model no. USAV01, will be subheading 9403.20.0050, HTSUS, which provides for " Other furniture and parts thereof: Other metal furniture: Household: Other: Other.” The rate of duty will be free.

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

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9403.20.0050, HTSUS, unless specifically excluded, are subject to an 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 9403.20.0050, 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.

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 Seth Mazze at [email protected].


Steven A. Mack
National Commodity Specialist Division