CLA-2-59:OT:RR:NC:N2:350
John Jordan
CARR North America LLC
1658 GAR Highway, Unit 6
Swansea, MA 02777
RE: The tariff classification of a polyurethane coated fabric from Turkey
Dear Mr. Jordan:
In your letter dated January 8, 2025, you requested a tariff classification ruling. Your submission included a
coated fabric which was forwarded to the Customs and Border Protection (“CBP”) Laboratory for analysis.
The sample submitted, style “CARRFLEX® CFX1011” is said to be a specialized coated fabric for use as a
mattress surface in prisons and other incarceration units. In your submission you state that the fiber
composition of the sample is 71 percent polyurethane, 26 percent polyester, and 3 percent glass fibers.
The CBP Laboratory has determined that the sample is composed of a weft knit polyester fabric impregnated,
coated, covered or laminated with a polyurethane type cellular plastic material. The textile fabric contains
manmade polyester fibers which have been placed between the fabric layer and the plastic material.
The CBP Laboratory’s analysis of the composition of the sample is roughly on par with your submission,
other than for your claim of the material containing glass fibers. No glass fibers were found to be contained
within the combined material, only polyester fibers.
The applicable subheading for fabric CARRFLEX® CFX1011 will be 5903.20.2000, Harmonized Tariff
Schedule of the United States (“HTSUS”), which provides for “Textile fabrics impregnated, coated, covered
or laminated with plastics, other than those of heading 5902: With polyurethane: Of man-made fibers: Other:
Over 70 percent by weight of rubber or plastics. The general rate of duty will be Free.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of Turkey will be
subject to an additional ad valorem rate of duty of 15 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.64, in addition to subheading
5903.20.2000, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 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 Code of Federal Regulations (19 CFR
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 Michael Capanna at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division