CLA-2-42:OT:RR:NC:N4:441
Kari Aiduk
Mohawk Global Logistics
123 Air Cargo Rd
North Syracuse, NY 13212
RE: The tariff classification of a trunk from Mexico
Dear Ms. Aiduk:
In your letter dated May 15, 2025, you requested a tariff classification ruling. You provided photographs and
descriptive literature for our review.
The article at issue, which you referred to as the “RB48 Universal Storage Chest” is a trunk constructed of
stainless steel. It measures 48” L“ x 24.25” W x 25” H. You have indicated that the article is designed to be
used on job sites, mounted in truck beds, used in garages, public parks, other industrial applications, and is
intended for the safe storage of tools. Its primary purpose is to safely transport the contents from one
location, such as a garage, to another location, such as a work site. The secondary purpose is to store,
organize, and protect the contents while in transit as well as when not in use.
You suggested classifying article in Heading 8708, Harmonized Tariff Schedule of the United States
(HTSUS), which provides for motor vehicle’s parts and accessories. We disagree.
The General Rules of Interpretation ("GRIs") govern classification of goods under the HTSUS. GRI 1
provides that classification shall be determined according to the terms of the headings of the tariff schedule
and any relative section or chapter notes. Additional U.S. Note 1 (c) states “a provision for parts of an article
covers products solely or principally used as a part of such articles, but a provision for "parts" or "parts and
accessories" shall not prevail over a specific provision for such part or accessory.” Since the article is more
specifically described elsewhere in the tariff, classification of the storage chest in heading 8708, HTSUS, is
precluded.
You also propose classification of the article as furniture in subheading 9403.20.0090, HTSUS, which
provides for “Other furniture and parts thereof: Other metal furniture: Other: Other.” We disagree.
The competing headings are 9403 “Other furniture and parts thereof” vs. 4202 “Trunks, suitcases, vanity
cases, attaché cases, briefcases, school satchels, spectacle cases, binocular cases, camera cases, musical
instrument cases, gun cases, holsters and similar containers; traveling bags, insulated food or beverage bags,
toiletry bags, knapsacks and backpacks, handbags, shopping bags, wallets, purses, map cases, cigarette cases,
tobacco pouches, tool bags, sports bags, bottle cases, jewelry boxes, powder cases, cutlery cases and similar
containers, of leather or of composition leather, of sheeting of plastics, of textile materials, of vulcanized
fiber or of paperboard, or wholly or mainly covered with such materials or with paper:”
This office notes that both heading 4202 and heading 9403 are eo nominee provisions. Furthermore, we note
that the subject turnk meets the general requirements of furniture in that it is floor standing, equips a dwelling
(vehicles are included), is used by people, and performs the function of storage.
However, based upon the submitted literature and general product knowledge, this office believes that the
principal use of the subject trunk is to carry articles in the bed of a pickup truck and not to store them on a job
site or other location. There is ample precedent in the Customs Rulings Online Search System (CROSS) of
Thule-type car carriers, motorcycle cases and scooter cases being classified in heading 4202. (See HQ
964859, HQ 965717, HQ 956047, HQ 8002354, NY A84170.) This article is akin to those.
Based upon the foregoing analysis, the subject trunk should be classified in heading 4202 rather than in
heading 9403.
The applicable subheading for the trunk will be 4202.19.0000, Harmonized Tariff Schedule of the United
States (HTSUS), which provides for trunks, suitcases, vanity cases, and similar containers, other. The general
rate of duty will be 20 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% ad valorem rate of duty.
At the time of entry, you must report the Chapter 99 heading applicable to your product’s classification,
9903.01.25, in addition to subheading 4202.19.0000, 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,
(for)
Steven A. Mack
Director
National Commodity Specialist Division