CLA-2-46:OT:RR:NC:4:434
Grace Chen
Zhejiang Hengtai Crafts Manufacturing Co., Ltd.
3-4F, NO 655, Jichang Road
YIWU 322000
China
RE: The tariff classification of decorative wreaths from China
Dear Ms. Chen:
In your letter, dated February 27, 2025, you requested a tariff classification ruling for a door wreath. In lieu of samples, photos and a detailed description were submitted for our review.
The item under consideration is a decorative door wreath, which measures approximately 22” in diameter. The underlying circular wreath form is fashioned from bundled dried vine, Vitis Vinefera, wrapped with wire. The bottom several inches of the vine wreath form is bare and visible when displayed. The remaining portion of the wreath is decorated with sprays of artificial evergreen and natural pinecones. A textile bow is mounted at the top of the wreath, and two plastic, decorative bells (no clappers inside) hang in the middle.
The dried vines meet the definition of plaiting materials, as set forth in Note 1 to Chapter 46, Harmonized Tariff Schedule of the United States (HTSUS), which states:
In this chapter the expression "plaiting materials" means materials in a state or form suitable for plaiting, interlacing or similar processes; it includes straw, osier or willow, bamboos, rattans, rushes, reeds, strips of wood, strips of other vegetable material (for example, strips of bark, narrow leaves and raffia or other strips obtained from broad leaves), unspun natural textile fibers, monofilament and strip and the like of plastics and strips of paper, but not strips of leather or composition leather or of felt or nonwovens, human hair, horsehair, textile rovings or yarns, or monofilament and strip and the like of chapter 54.
The wreath is a composite article made of plaiting materials (vines), polyester fabric (bow), plastic (artificial foliage and bells), pinecones, and iron wire. Classification of merchandise under the HTSUS is in accordance with the General Rules of Interpretation (GRIs). GRI 3(b) provides that composite articles consisting of different materials or made up of different components shall be classified as if they consisted of the material or component which gives them their essential character, which may be determined by the nature of the material or component, its bulk, quantity, weight, or value, or by the role of a constituent material in relation to the use of the article.
The vines, the artificial foliage, pinecones, bow, and bells all contribute to the decorative appeal of the wreaths. The vines additionally provide the wreath’s structure and a base on which to mount the foliage etc. Due to the vine’s dual role providing both structural and decorative elements, we find that the vines confer the essential character. We also note that, per your provided figures, the vines predominate by weight and value over the other components.
The applicable subheading for the wreath will be 4602.19.6000, HTSUS, which provides for “Basketwork, wickerwork and other articles, made directly to shape from plaiting materials or made up from articles of heading 4601; articles of loofah: Of vegetable materials: Other: Other: Other: Wickerwork.” The wreaths constitute wickerwork, which is commonly defined as products made of flexible, vegetable twigs or rods, in contrast to strips, filaments, parts of leaves, etc. The column one, general 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 the World Wide Web at https://hts.usitc.gov/current.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 4602.19.6000, 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, 9903.88.03, in addition to subheading 4602.19.6000, HTSUS, listed above.
For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, 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.
Effective February 4, 2025, in accordance with the President’s Executive Order “Imposing Duties to Address the Synthetic Opioid Supply Chain in the People’s Republic of China,” all products of China and Hong Kong as provided by heading 9903.01.20 in Section XXII, Chapter 99, Subchapter III, U.S. Note 2(s), HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.20, in addition to subheading 4602.19.6000, 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 Notes cited above and the applicable Chapter 99 subheadings.
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.
The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading.
The importation of this product may be subject to import regulations administered by the U.S. Department of Agriculture (U.S.D.A.). Information regarding applicable regulations administered by the U.S.D.A. may be addressed to that agency at the following location:
U.S. Department of Agriculture
A.P.H.I.S., PPQ
4700 River Road, Unit 136
Riverdale, MD 20737
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 Charlene Miller at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division