CLA-2-94:OT:RR:NC:N5:433
Fui Yang Yap
Lifely Inc
239 Fourth Ave, Ste 1401 #5865
Pittsburgh, PA 15222
RE: The tariff classification of seating components from Thailand.
Dear Fui Yang Yap:
In your letter dated June 12, 2025, you requested a binding tariff classification ruling. In lieu of samples,
technical and illustrative literature, and product descriptions were provided for your review.
Item 1, the “Full Sofabed - Dark Gray (V2DB-DKGY), item 2, the “Queen Sofabed-Dark Gray
(V2QB-DKGY),” item 3, the “Single Sofabed-Dark Gray (V2OB-DKGY),” item 4, the “Chaise
Sofabed-Dark Gray (V2CH-DKGY),” and item 5, the “Corner Sofabed-Dark Gray (V2TB-DKGY),” are
modular upholstered seats constructed of pocket coil springs and foam encased in textile with Velcro straps.
Each seat is not constructed of metal, wood, or plastic straight, concave, or convex frame rails, but primarily
foam cushions. Items 1 through 5 are standalone and separate seating components; they do not form a
unitary whole, they do not have connection posts or brackets, and they are not permanently affixed to one
another. Seating is provided for one or more individuals. Items 1 through 5 are separate and independent
components that can be configured and reconfigured. When configured and reconfigured, each seating
component may alternatively function as a bed, however, each seating component does not have a separate
and removeable mattress component. Each of the seating components will be made available for retail as
both individual units and as modular combinations (2-piece, 3-piece, or 4-piece sectionals) depending on
customer preference and will include accent pillows.
Item 6, the “Armrest/Backrest (V2 RMST),” is an upholstered seat component constructed of particleboard
and foam encased in textile with Velcro strips. The seating components are not permanently affixed to the
structural frame of a seat. Velcro straps are located at the base of the armrests/backrests; the Velcro straps
allow the seating components to be positioned, repositioned, and removed according to user preference. The
dimensions of the armrest/backrest components approximate 20.1” width, 6.89” in depth, and 4.33” in
height. The armrest/backrest components will be imported and sold separately.
Item 7, the “Ottoman-Dark Gray (V2OS-DKGY),” is an upholstered seat affixed to a plywood and wood
frame. Seating is provided for a single individual, and a storage compartment is located at the base of the
seat foundation. The ottoman cushion is constructed of foam encased in textile. Textile webbing and an “S”
spring located beneath the seat foundation provides comfort, support, and is permanently affixed to the
wooden frame. The ottoman contains no exposed solid wood. The ottoman dimensions are 30.5” in width,
30.5” in length, and 16.9” in height. The ottoman will be imported and sold separately.
The ruling request seeks classification of items 1 thru 7 in subheading 9401.61.2011, Harmonized Tariff
Schedule of the United States, (HTSUS), which provides for “Seats (other than those of heading 9402),
whether or not convertible into beds, and parts thereof: Other seats, with wooden frames: Upholstered:
Chairs: Of teak: Household: Of plantation-harvested teak.” We disagree. The wood inserts incorporated
into the armrest and backrest components are not of teak wood.
The applicable subheading for items 1 thru 5, if made of reinforced or laminated plastics, will be
9401.80.2011, HTSUS, which provides for “Seats (other than those of heading 9402), whether or not
convertible into beds, and parts thereof: Other seats: Of rubber or plastics: Of reinforced or laminated
plastics: Other household.” The rate of duty will be free.
The applicable subheading for items 1 thru 5, if not made of reinforced or laminated plastics, will be
9401.80.4046, HTSUS, which provides for “Seats (other than those of heading 9402), whether or not
convertible into beds, and parts thereof: Other seats: Of rubber or plastic: Other: Other: Other. The general
rate of duty will be free.
The applicable subheading for item 6 will be 9401.99.3580, HTSUS, which provides for “Seats (other than
those of heading 9402), whether or not convertible into beds, and parts thereof: Parts: Other: Of rubber or
plastics: Other.” The rate of duty will be free.
The applicable subheading for item 7 will be 9401.61.4011, HTSUS, which provides for “Seats (other than
those of heading 9402), whether or not convertible into beds, and parts thereof: Other seats, with wooden
frames: Upholstered: Chairs: Other: Other household.” The rate of duty will be free.
Trade Remedy:
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,
including Thailand, 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 subheadings 9401.61.4011, 9401.80.2011, 9401.80.4046 or 9401.99.3580, 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 Dharmendra Lilia at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division