CLA-2:49:OT:RR:NC:4:434
Tirta Halim
T Customs Broker, Inc.
5777 W. Century Blvd.
Los Angeles, CA 90045
RE: The tariff classification of drying racks from Malaysia
Dear Mr. Halim:
In your letter, dated April 4, 2025, you requested a tariff classification ruling on behalf of your client,
Specified Components Co. Videos and descriptive information were provided for our review in lieu of
samples.
The subject article is identified as the “DryAway Eco-Friendly Laundry Drying System.” It consists of
drying racks on which to dry clothing instead of machine-drying. Each rack measures approximately 83
inches tall by 29 inches wide. The outer frame is wood (rubberwood), and the five horizontal hanging rods
and one horizontal stabilization rod are aluminum. The components are purchased unassembled, with one
box containing the components for two complete racks. Once assembled, the racks will hang from above in
an open-front cabinet or closet in the owner’s home. They are designed to slide out individually and provide
adequate space between the racks to allow air flow. Complete hardware for assembly and mounting is
included. You also provided a breakdown by weight and value of the individual components.
Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is in
accordance with the General Rules of Interpretation (GRIs). GRI 3(b) provides that composite goods
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 drying rack is a composite article made up primarily of the wooden
frame and aluminum rungs. The essential character of the article is imparted by the wooden frame, which
provides the indispensable structure of the rack and allows it to be mounted and hung. The wood also
heavily predominates by weight and value over the aluminum components.
The applicable subheading for the drying racks will be 4420.90.8000, HTSUS, which provides for ?wooden
articles of furniture not falling within chapter 94: Other?? The column one, general rate of duty will be 3.2
percent ad valorem.
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.
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, 9903.01.25, in addition to subheading
4420.90.8000 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.
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 Charlene Miller at
[email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division