CLA-2-42:OT:RR:NC:N4: 441
Deana Smith
The William Carter Company
3438 Peachtree Road
Atlanta, GA 30326
RE: The tariff classification of a diaper pouch from Cambodia
Dear Ms. Smith:
In your letter dated May 1, 2025, you requested a tariff classification ruling. You have submitted a sample,
which will be returned to you under separate cover.
The submitted sample, which you referred to as the “Diaper Changing Station,” is a diaper pouch. In your
submission, you stated that it is made of 88% nylon and 12% polyester, which are both man-made materials.
The article is designed to provide storage, protection, portability, and organization to personal effects related
to infant care during travel. It features a front flap and a button loop closure. The bottom features a zippered
closure. The interior features two compartments. The article features a foldable diaper pad permanently
affixed to the back of the pouch. The pad is secured with an elastic band. The pouch measures approximately
approximately 9 inches (L) X 10.5 inches (H) X 2.5 inches (W).
In your request, you propose classification of the diaper changing station in subheading 3924.90.1050,
Harmonized Tariff Schedule of the United States, (HTSUS), which provides for “Tableware, kitchenware,
other household articles and hygienic or toilet articles, of plastics: Other: Curtains and drapes, including pan
els and valances; napkins, table covers, mats, scarves, runners, doilies, centerpieces, antimacassars and
furniture slipcovers; and like furnishings. Other.” However, we disagree. The article is precluded from
classification in Chapter 39, by note 2(m).”
The diaper pouch and diaper pad are considered composite goods, General Rule of Interpretation (GRI) 3(b)
of the HTSUS noted. The essential character is imparted by the diaper pouch as that is the principal
component which predominates in weight, bulk, and use. Moreover, the foldable diaper pad is optional
component that will be used as needed.
The applicable subheading for the diaper pouch will be 4202.92.9100, HTSUS, which provides for other
containers and cases, with outer surface of sheeting of plastic or of textile materials, other, other, with outer
surface of textile materials, of man-made fibers (except jewelry boxes of a kind normally sold at retail with
their contents). The general rate of duty will be 17.6 percent ad valorem.
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. At this time products from all 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., 9903.01.25, in addition to subheading
4202.92.9100, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling?s issuance. 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/.
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 and Border Protection
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, please contact
National Import Specialist Vikki Lazaro at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division