CLA-2-42:OT:RR:NC:N4:441
Ms. Mariana Del Rio Kostenwein
Simon Gluck & Kane LLP
535 Fifth Avenue
New York, NY 10017
RE: The tariff classification of a molded plastic cooler from Cambodia
Dear Ms. Del Rio Kostenwein:
In your letter dated March 14, 2024, you requested a tariff classification ruling on behalf of your client, California Innovations, Inc. You submitted photographs and descriptive literature for our review.
The article at issue, which you referred to as the “Patio Cooler on the Go,” is a hard-sided plastic cooler with an optional wheeled cart. In your request, you stated that the cooler is constructed of molded plastic. Based on the submitted photos, it is not covered or coated with another material on the outer surface. The cooler is structured and rigid on all sides. It features one handle on each side and two latches to secure the lid. It also features a bin, a divider, and a removable light. The article is designed to provide storage, protection, portability, and organization to food and beverages while traveling. It measures approximately 62 inches (L) x 20 inches (W) x 42 inches (H).
The plastic cooler and the wheeled cart are considered composite goods in accordance with General Rule of Interpretation 3(b) of the Harmonized Tariff Schedule of the United States (HTSUS). The two components are adapted to each other by means of a connection system. Each component is mounted with half of several specialized latches which, when connected, join the two components together. For additional stabilization, the cart also has four indentations sized and shaped to connect with the base of the cooler. The cooler may be used with or without the wheeled cart. The wheeled cart is an optional component that will be used as needed. The primary purpose of the article is to maintain the temperature of food and beverages while being transported to a second location. As such, the essential character is imparted by the cooler.
The applicable subheading for the molded plastic cooler will be 4202.12.2120, HTSUS, which provides for trunks, suitcases, and similar containers: with outer surface of plastics: structured, rigid on all sides. The general rate of duty will be 20 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.
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.
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 Vikki Lazaro at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division