CLA-2-94:OT:RR:NC:N4:463
Natalie M. Muurisepp
Hooker Furnishings Corporation
2485 Penny Rd.
High Point, NC 27265
RE: The classification of a hall chest from Vietnam
Dear Ms. Muurisepp:
This ruling is being issued in response to your letter dated April 18, 2025, requesting the tariff classification
of a hall chest. In lieu of samples, a picture, value and weight information were provided.
The subject article is identified as the Holy Cow Chest, product number 628-85004. It is a three-drawer chest
of drawers that measures 38" (W) x 18" (D) x 32" (H). It has a sheet metal top and sides, and rectangular
metal legs. The drawers are made of rubberwood and plywood. The drawers are faced in cowhide with cow
hair. Each drawer has a long horizontal metal pull stretching across the drawer face. The provided value
information indicates that the metal and the cowhide are of similar value and much more expensive than the
wood components (plywood, rubberwood and MDF). The weight information indicates that the wood
components weigh somewhat more than the metal, and that by weight, the cowhide is of little consequence.
The chest is made in Vietnam and is shipped assembled to the United States.
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.
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
hall chest is within the meaning of furniture as described by the General ENs to Chapter 94 of the HTSUS.
Since the article is composed of different materials (steel, wood, and leather), it is considered a composite
good for tariff purposes. The ENs to the HTSUS, GRI 3(b) (VIII), state that “the factor which determines
essential character will vary between different kinds of goods. It may, for example, be determined by the
nature of the materials or components, its bulk, quantity, weight or value, or by the role of a constituent
material in relation to the use of the goods.” When the essential character of a composite good can be
determined, the whole product is classified as if it consisted only of the material or component that imparts
the essential character to the composite good. GRI 3(c) provides that when goods cannot be classified by
reference to GRI 3(a) or 3(b), they are to be classified in the heading that occurs last in numerical order
among those that equally merit consideration.
Although a hall chest should be aesthetically pleasing, its utility is derived from its ability to store, hold, and
display articles. With respect to the subject Holy Cow Chest, the structure and the majority of the outer
surface are metal, as are the legs. In addition to the structure and the majority of the outer surface being
metal, the single most expensive material used to produce the chest is also metal. The metal components are
not the heaviest—that would be the wood components—however, they are a close second. The cowhide
drawer fronts are the second most expensive component in the subject hall chest, and although they are
important for the unique aesthetics, they add nothing to the subject chest’s utility.
Based upon the aforementioned analysis, this office finds that the metal frame imparts the essential character
to the subject hall chest.
The applicable classification for the Holy Cow Chest, product number 628-85004, will be subheading
9403.20.0050, HTSUS, which provides for which provides for “Other furniture and parts thereof: Other
metal furniture: Household: Other: Other.” The general rate of duty will be free.
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 9403.20.0050,
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 9403.20.0050, 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 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 CFR 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