CLA-2-94:OT:RR:NC:N4:463
Matthew Clark
Kuehne + Nagel Inc.
20000 S. Western Ave.
Torrance, CA 90501
RE: The tariff classification of a smart locker from China
Dear Mr. Clark:
This ruling is being issued in response to your letter dated May 7, 2025, requesting a tariff classification
determination on behalf of your client, Merchants International, Inc., on a smart locker. In lieu of a sample,
pictures and a product description were provided.
The subject article, identified as the Minnow Pod Q7, model number MPP-Q7, is a rectangular floor-standing
wooden locker cabinet that will be used to temporarily store orders from food delivery services. The locker
measures approximately 37" (W) x 25" (D) x 72" (H) (with the base) and approximately 31" (W) x 17" (D) x
70" (H) (without the base). It is made primarily from 3/4" thick marine-grade plywood and 3/4" thick
medium density fiberboard (MDF). The locker is comprised of seven storage cubbies that measure
approximately 13" (W) x 16" (D) x 15" (H). There is a touchscreen used to access each locked cubby door.
Power is supplied from a cord extending from the back of the unit. The locker weighs 233 lbs. and is made
in China. See image below:
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
article is within the meaning of furniture as described by the General ENs to Chapter 94 of the HTSUS.
You suggest classification in subheading 9403.60.8093, HTSUS, as wooden furniture. We agree.
The applicable classification for the Minnow Pod Q7, model number MPP-Q7, will be subheading
9403.60.8093, HTSUS, which provides for “Other furniture and parts thereof: Other wooden furniture: Other:
Other: Other.” 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 9403.60.8093, 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. 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
9403.60.8093, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 9403.60.8093, 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 9403.60.8093, 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