CLA-2-94:OT:RR:NC:N5:433
Taichi Kumazawa
Sun-Wa Technos America, Inc.
3100 Bristol Street, Suite 450
Costa Mesa, CA 92626
RE: The tariff classification of metal furniture from Vietnam
Dear Taichi Kumazawa:
In your letter dated July 16, 2025, you requested a tariff classification ruling. In lieu of samples, technical
and illustrative literature, and a product description were provided.
The “Mini-Max Equipment Front End Module (EFEM)” is an unassembled and unequipped metal
semiconductor cabinet frame. The powder coated metal frame is constructed of 65% cold rolled steel, 30%
aluminum (6061-T6), 3% plastic (acrylic, polycarbonate), and 2% stainless steel. The cabinet frame will
contain panels, partitions, frame rails, doors, protector plates, washers, hinges, stops, and screws. The
cabinet frame will provide storage and structural support for large and small semiconductor equipment. The
dimensions will approximate 47.24” in length, 31.69” in width, and 80.97” in height.
Information provided identifies a light tower, robot motion controller, robot body arm, end effector,
pre-aligner, ID readers, fan filter unit (FFU), 2 load ports, power and signal electronics, user interface
(computer, monitor), and other compatible devices and subassemblies, however they are not explicitly
included with the instant article at the time of U.S. importation. Rulings are issued with regard to specific
facts. The light tower, robot motion controller, robot body arm, power and signal electronics, and other
compatible devices will be imported separately; they are not under consideration in this ruling letter.
The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitutes the
official interpretation of the Harmonized System at the international level.
The ENs to Chapter 94 of the Harmonized Tariff Schedule (HTS), for “Furniture,” states: “the term
“furniture” means: Any “moveable” 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, cafes, restaurants, laboratories, hospitals dentists’ surgeries, etc., or
ships, aircraft, railway coaches, motor vehicles, caravan-trailers or similar means of transport. (It should be
noted that, for the purposes of this Chapter, articles are considered to be “movable” furniture even if they are
designed for bolting, etc., to the floor, e.g., chairs for use on ships). Similar articles (seats, chairs, etc.,) for
use in gardens, squares, promenades, etc., are also included in this category.”
Further, the ENs to Chapter 94, heading 9403 of the HTS, provides “This heading covers furniture and parts
thereof, not covered by the previous headings. It includes furniture for general use (e.g., cupboards, show
cases, tables, telephone stands, writing desks, escritoires, book cases, and other shelved furniture (including
single shelves presented with supports for fixing them to the wall), etc.), and also furniture for special uses.”
Heading 9403 item (2) includes furniture for “Offices, such as: cloth lockers, filing cabinets, filing
trolleys, card index files, etc.”
Heading 9403 item (6) includes furniture for “Laboratories or technical offices, such as: microscope
tables; laboratory benches (whether or not with glass cases, gas nozzles and tap fittings, etc.);
fumecupboards; unequipped drawing tables.”
The “Mini-Max Equipment Front End Module (EFEM)” is within the construct of Chapter 94 and heading
9403 items (2) and (6); the unequipped metal cabinet is furniture that will equip an office, laboratory, or
technical office. After assembly, computer equipment, diagnostic tools, and other semiconductor equipment
will be incorporated into the metal frame cabinet.
The applicable subheading for the subject merchandise will be 9403.10.0040, Harmonized Tariff Schedule of
the United States (HTSUS), which provides “Other furniture and parts thereof: Metal furniture of a kind used
in offices, Other.” The general rate of duty will be free.
Trade Remedy:
On March 12, 2025, Presidential proclamation 10895 imposed additional tariffs on certain derivative
aluminum products. Additional duties for derivative aluminum products of 50 percent are reflected in
Chapter 99, headings 9903.85.04, 9903.85.07, and 9903.85.08. Products provided by heading 9903.85.08, as
well as products of Chapter 76 provided by 9903.85.04 and 9903.85.07, will be subject to a duty of 50
percent upon the value of the aluminum content. At the time of entry, you must report the Chapter 99 heading
applicable to your product classification, i.e. 9903.85.08, in addition to subheading 9403.10.0040, HTSUS.
Derivative aluminum articles processed in another country from aluminum articles that were smelted and
cast in the United States, provided for in heading 9903.85.09, 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. 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, 9403.10.0040, 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