CLA-2-94:OT:RR:NC:N5:433
Maureen Sharma
Mullally International Inc
1305 Republican St.
Seattle, WA 98109
RE: The tariff classification and country of origin of metal furniture.
Dear Mrs. Sharma:
In your letter dated July 14, 2025, you requested a tariff classification ruling. In lieu of samples, illustrative
literature, a description, and a manufacturing synopsis are provided for review.
Model number 1934017, the “Planter Caddy Stand,” is a powder coated steel metal circular platform with
swivel casters that is for the display and movement of potted plants. The top plate is constructed of
cold-rolled sheet steel with symmetrical geometric cutouts emanating from the center for drainage. A steel
ring of square tubing is welded to the underside of the top plate for strength. The steel metal top plate sits
atop the four steel swivel casters with plastic treads, two of which have locking brakes. The casters are
affixed to nuts welded to the underside of the top plate. The planter caddy stands dimensions approximate
15” in diameter, 3” in height, and will have a maximum weight capacity of 250 lbs. In the condition at the
time of U.S. importation, the planter caddy stand will be packaged 2 units per retail carton.
The applicable subheading for the subject merchandise will be 9403.20.0050, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for “Other metal furniture and parts thereof: Other metal
furniture: Household: Other: Other.” The general rate of duty will be free.
Sourcing Scenario:
The ruling request outlines an operation wherein the steel sheet metal and the caster components (stem,
bearing assembly, wheel housing, wheel assembly, nuts, plastic tires) will be sourced in China. The steel
sheet metal will be shipped and exported to Vietnam for manufacture and then to Cambodia for finishing
operations. The Chinese caster components will be exported to Cambodia for assembly. In Cambodia, the
complete and assembled article will then be exported to the United States.
Per your submission, in Vietnam, (1) the Chinese rolled steel sheeting will undergo primary manufacturing
operations that include cutting, punching, and stamping into rough round shaped plates with symmetrical
geometric designs and patterns using a combination of 200 ton and 260 ton pressing machines. The
incomplete, unfinished, and unassembled planter caddy components will then be shipped to Cambodia for
finishing operations. In Cambodia, (1) the punched and stamped rough round shaped plates will be sorted
and examined for rust or damage, (2) the nuts will be spot welded to the top plate, (3) the top plate will
undergo grinding to remove excess slag, and (4) the top plate will then undergo metal finishing operations
(edge smoothing, degreasing, phosphating, cathode electroplating, powder coating), and then assembly of the
casters to the top plate. In Cambodia, the assembled planter caddy stand will be cleaned, inspected, packed,
labeled, and then exported to the United States. Photographs of these processes were provided.
Country of Origin:
When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,
Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a
substantial transformation will occur is whether an article emerges from a process with a new name,
character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v.
United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See
National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).
In the instant case, the Chinese steel sheets lose their identity during manufacture and undergo a substantial
transformation in Vietnam. The symmetrical geometric cutting, punching, and stamping operations
performed in Vietnam results in an article that has undergone a change in commercial designation or identity,
fundamental character, or commercial use. Furthermore, the Vietnamese manufacturing operations
performed constitutes more than minor processing when compared to the assembly and finishing operations
performed in Cambodia. In view of these facts, the country of origin for the metal furniture will be Vietnam.
Trade Remedy:
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter
99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as
products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 percent upon
the value of the steel content. At the time of entry, you must report the Chapter 99 heading applicable to your
product classification, i.e. 9903.81.91, in addition to subheading 9403.20.0050, HTSUS. Derivative iron or
steel products processed in another country from steel articles melted and poured in the United States,
provided for in heading 9903.81.92, are not subject to the additional ad valorem duties.
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 Vietnam, will be subject to an additional 10 percent ad valorem rate of duty. For products covered
by heading [9903.81.91] this additional duty applies to the [non-steel or non-aluminum] content of the
merchandise. 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 9403.20.0050, 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