CLA-2-67:OT:RR:NC:N4:415
Ryan Lickfeld
Geodis USA, LLC
5101 South Broad Street
Philadelphia, PA 19112
RE: The tariff classification of a decorative wreath from China.
Dear Mr. Lickfeld:
In your letter dated March 25, 2025, you requested a tariff classification ruling on behalf of your client, CVS
Pharmacy, Inc.
Images were provided in lieu of a sample.
The product under consideration is described as a fall themed wreath, item number 419456. This wreath is
constructed from rattan, plastic artificial foliage, and corn husks. Rattan and iron wire are used to form the
base structure, which is wholly obscured by the foliage. Your submission indicates the decorative plastic
foliage and corn husks are assembled and attached to the rattan core by binding or gluing.
We find this wreath meets the requirements set forth by heading 6702, specifically it resembles the natural
product, is assembled from various parts by binding or gluing, and is not subject to any of the listed
exclusions, making classification within this heading appropriate. At the subheading level, we hold the
opinion the plastic foliage imparts the essential character to this composite good, General Rules of
Interpretation 6 and 3(b) noted.
The applicable subheading for this fall themed wreath, item number 419456, will be 6702.10.2000,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[a]rtificial flowers, foliage
and fruit and parts thereof; articles made of artificial flowers, foliage or fruit: [o]f plastics: [a]ssembled by
binding with flexible materials such as wire, paper, textile materials, or foil, or by gluing or by similar
methods.” The column one, general rate of duty is 8.4 percent ad valorem.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. ?At the time of entry, you must report the applicable Chapter 99 heading, i.e., 9903.01.24, in addition
to subheadings 6702.10.2000, HTSUS, listed above.
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.? Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. ?Products from all other
countries will be subject to an additional 10 percent ad valorem rate of duty.? At the time of entry, you must
report the Chapter 99 heading applicable to your product classification, i.e., 9903.01.63, in addition to
subheadings 6702.10.2000, HTSUS, listed above.
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/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 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, contact
National Import Specialist Kristopher Burton at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division