CLA-2-94:OT:RR:NC:N4:463
Alex French
Carmichael International Service
1200 Corporate Center Dr.
Monterey Park, CA 90275
RE: The classification of weight racks from China
Dear Mr. Nickell:
In your letter dated April 1, 2025, you requested a tariff classification determination on behalf of your client,
Hoist Fitness Systems, on weight racks. In lieu of samples, pictures and product descriptions were provided.
The subject articles are weight racks, identified below.
The HF-5459 Vertical Dumbbell Rack is a vertical steel storage rack designed to hold 5 pairs of dumbbells.
It is a heavy-duty metal rack designed to hold two vertical rows of dumbbells in polypropylene-covered
“stacked” grooves. The rack measures 44"(H) x 19"(W) x 17"(D) weighs 44 lbs. and can hold up to 400 lbs.
The HF-5460 Vertical Dumbbell Rack is almost identical to the HF-5459 rack, above. The only difference
being that it holds 8 pairs of dumbbells, measures 52" high, weighs 51 lbs. and can hold up to 520 lbs.
The HF-5461-36 Horizontal Dumbbell Rack is a steel heavy-duty horizontal dumbbell storage rack designed
to hold hex dumbbells. It is comprised of two inclined parallel shelves supported by slightly inclined metal
legs on either side and a U-shaped foot extending behind the rack to the floor. The rack measures 43" (W) x
25" (D) x 36" (H), weighs 84 lbs., and can hold up to 600 lbs. per shelf. The HF-5461-OPT-36 variant is a
3-shelf design with the same measurements and weight, but a 1,080 lbs. capacity.
The HF-5461-48 Horizontal Dumbbell Rack is almost identical to the HF-5461-36 above. The only
difference being that it has a length of 55" and weighs 99 lbs. The HF-5461-OPT-48 variant is a 3-shelf
design with the same measurements and weight, but a 1,800 lbs. capacity.
The HF-5461-60 Horizontal Dumbbell Rack is also almost identical to the HF-5461-36 and HF-5461-48,
above. The only difference being it has a length of 67" and weighs 115 lbs. The HF-5461-OPT-60 variant is
a 3-shelf design with the same measurements and weight, but a 1,800 lbs. capacity.
The racks are made in China. See images below:
Vertical Rack Horizontal Rack With Optional 3rd shelf
Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is made in accordance
with the General Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods shall be
determined according to the terms of the headings of the tariff schedule and any relative section or chapter
notes. If the goods cannot be classified solely based on GRI 1, and if the headings and legal notes do not
otherwise require, the remaining GRIs 2 through 6 may then be applied in order.
You suggest the weight racks should be classified under subheading 9506.91.0030, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for "Articles and equipment for general physical
exercise, gymnastics, athletics, other sports (including table tennis) or outdoor games, not elsewhere specified
or included; swimming pools and wading pools; parts and accessories thereof; articles and equipment for
general physical exercise, gymnastics or athletics: Other: Other:. We disagree. Consistent with NYRLs
N009165 and R01856, the articles, which are designed to stand on the floor, and are used to store dumbbells,
are not classified in heading 9506, HTSUS.
In understanding the language of the HTSUS, the Explanatory Notes (ENs) of the Harmonized Commodity
Description and coding System, which constitutes the official interpretation of the Harmonized System at the
international level, may be utilized. The ENs, although not dispositive or legally binding, provide a
commentary on the scope of each heading and are generally indicative of the proper interpretation of the
HTSUS. The ENs to Chapter 94 of the HTSUS state, in relevant part, for the purposes of this Chapter, that
the term “furniture” means: (A): Any “movable” articles (not included under other more specific headings of
the Nomenclature), which have the essential characteristic that they are constructed for placing on the floor or
ground, and which are used, mainly with a utilitarian purpose, to equip private dwellings, hotels, theatres,
cinemas, offices, churches, schools, cafés, restaurants, laboratories, hospitals, dentists, surgeries, etc., or
ships, aircraft, railway coaches, motor vehicles, caravan-trailers or similar means of transport. The subject
articles are within the meaning of furniture as described by the General ENs to Chapter 94 of the HTSUS.
The applicable classification for the weight racks, with model numbers HF-5459, HF-5460, HF-5461-36,
HF-5461-OPT-36, HF-5461-48, HF-5461-OPT-48, HF-5461-60, and HF-5461-OPT-60 will be, will be
subheading 9403.20.0082, HTSUS, which provides for “Other furniture and parts thereof: Other metal
furniture: Other: Counters, lockers, racks, display cases, shelves, partitions and similar fixtures: Steel racks,
other than those described in statistical reporting number 9403.20.0075.” The general rate of duty will be
free.
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 subheading 9403.20.0082, HTSUS, listed above.
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 25 percent are reflected in Chapter
99, headings 9903.81.89 and 9903.81.90. Products provided by heading 9903.81.91 will be subject to a duty
of 25 percent upon the value of the steel content. At the time of entry, you must report the Chapter 99
heading applicable to your product classification, i.e. 9903.81.91, in addition to subheading 9403.20.0082,
HTSUS. Derivative iron or steel products processed in another country from steel articles melted and poured
in the United States, provided for in heading 9903.81.92, are not subject to the additional ad valorem duties.
Please note that derivative steel products admitted to a U.S. foreign trade zone under “privileged foreign
status” before March 12, 2025, and entered for consumption on or after March 12, 2025, may be subject to
additional duties under heading 9903.81.93, HTSUS.
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. Your product falls within an
excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your
product classification, i.e. 9903.01.33, in addition to subheading 9403.20.0082, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 9403.20.0082, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report Chapter 99 subheading 9903.88.03 in
addition to subheading 9403.20.0082, 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, 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 on the internet 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 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. If the facts are modified in any way, or if the goods do not conform to
these facts at the time of importation, you should bring this to the attention of 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 Title 19 of the Code of Federal Regulations
(19 C.F.R. Part 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 Seth Mazze at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division