CLA-2-96:OT:RR:NC:N4:422
Mr. Zachary Sutton
Base Brands (Reduce)
1170 Howell Mill Rd. Ste 400
Atlanta, GA 30318
RE: The tariff classification of the Aspen tumbler from China
Dear Mr. Sutton:
In your letter dated June 2, 2025, you requested a tariff classification ruling. A sample was submitted and
sent to the Customs laboratory for analysis. Internet research on the importer’s website was also conducted.
The merchandise under consideration is referred to as the Aspen tumbler. A sample of the tumbler was
submitted with your ruling request and was forwarded to the Customs and Border Protection Laboratory for
analysis. This analysis has been completed.
The Aspen tumbler is a 20-ounce drinking vessel designed for consuming cold beverages. It measures
approximately 10 inches high by 3.7 inches long by 3.7 inches wide and has a base diameter of 2.91 inches. It
consists of a blue stainless steel outer sleeve with a flat bottom, a borosilicate glass inner, a removable plastic
top lid with a hole, and a plastic straw. The portable drinking vessel is designed to keep beverages cold for an
extended period of time.
Laboratory analysis of the Aspen tumbler determined that the outer vessel is stainless steel and is a double
wall insulated vacuum vessel. The bottom of the vessel is not intended for hot liquids. The borosilicate glass
is not pressed and toughened (specially tempered).
The applicable subheading for the Aspen tumbler will be 9617.00.1000, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for “Vacuum flasks and other vacuum vessels, complete; parts
thereof other than glass inners: Vessels: Having a capacity not exceeding 1 liter.” The general rate of duty
will be 7.2 percent ad valorem.
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 9617.00.1000, 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, products of China
are not subject to reciprocal tariffs. 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 9617.00.1000, 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 Dana L. Giammanco at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division