CLA-2-63:OT:RR:NC:N3:351
Mr. Godfrey Yeung
Smart Concept Trading Limited
Flat C&D, 12th floor Mai Wah Industrial Building
1-7 Wah Sing Street Kwai Chung China
RE: The tariff classification of a shoe drying mat with tray from China
Dear Mr. Yeung:
In your letter dated October 25, 2024, you requested a tariff classification ruling. A sample of the shoe drying mat with tray was provided to this office and will be retained for training purposes.
SKU# BH562980038021, described as a “Shoe Drying Mat with Tray,” consists of a textile mat and two removable plastic ventilated racks designed to elevate your shoes allowing water to drip off. The shoe drying mat is intended to absorb the water and keep the floor clean and dry. The mat is composed of three layers: a 100 percent polyester knitted mesh fabric top layer; a 100 percent polyurethane foam middle layer; and a 100 percent polyester knitted terry fabric bottom layer. The rectangular shaped mat measures 35½ inches in length by 13 inches in width and is finished with a â… inch wide 100 percent polyester knitted binding. The mat features an elastic band sewn to the mesh fabric, so when not in use the shoe drying mat can be folded and stored. The mat is also washable. Each rectangular shaped rack is composed of 100 percent polypropylene and measures 8¾ inches in length by 13 inches in width. Each rack has a lip on each of the ends that fits over the side of the mat and can slide back and forth along the mat as desired. You state the items are packaged and sold together.
The shoe drying mat with tray is a composite good consisting of a made-up textile mat (heading 6307) and a plastic molded rack (chapter 39). General Rule of Interpretation (GRI) 1, Harmonized Tariff Schedule of the United States (HTSUS), states in part that for legal purposes, classification shall be determined according to the terms of the headings, any relative section or chapter notes and, unless otherwise required, according to the remaining GRI’s taken in order. Goods that are, prima facie, classifiable under two or more headings, are classifiable in accordance with GRI 3. GRI 3(a) states that the heading which provides the most specific description shall be preferred to headings providing a more general description. However, when two or more headings refer to part only of the items in a composite good, those headings are to be regarded as equally specific in relation to the goods, even if one of them gives a more complete or precise description of the good. As such, they are regarded as equally specific and classification of the composite good is to be determined by GRI 3(b) or GRI 3(c). GRI 3(b) states in part that composite goods, which cannot be classified by reference to GRI 3(a), are to be classified as if they consisted of the component which gives them their essential character. In this case, we find the essential character of the shoe drying mat with tray to be the made up textile mat.
The applicable subheading for the shoe drying mat with tray will be 6307.90.9891, HTSUS, which provides for “Other made-up articles, including dress patterns: Other: Other: Other: Other: Other.” The rate of duty will be 7 percent ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 6307.90.9891, 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 6307.90.9891, 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 https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, 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 at https://hts.usitc.gov/.
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 and Border Protection 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, please contact National Import Specialist Kristine Dodge at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division