CLA-2-94:OT:RR:NC:N5:433
Ron Knutson
San Pacific International Inc.
377 Swift Avenue
South San Francisco, CA 94080
RE: The tariff classification of metal furniture from China
Dear Mr. Knutson:
In your letter dated July 3, 2025, you requested a tariff classification ruling. In lieu of samples, technical and
illustrative literature, and a product description were provided for review.
Item 33686, the “Lovebird Home Décor Coat Rack,” is a metal frame coat rack constructed of 100% recycled
aluminum. The three-dimensional piece depicts birds and tree branch posts affixed to a center column. The
functional coat rack allows for the placement of coats, hats, gloves, scarves, umbrellas, and other objects.
The coat rack dimensions approximate 21” in width at the base, 69” in height, and weighs 12 lbs. The use of
the coat rack in a private dwelling, hotel, theatre, office, church, school, cafe, restaurant, laboratory, hospital,
or alternate setting is not readily apparent; the ultimate purchaser will determine the location and placement
of the furniture piece.
The applicable subheading for the subject merchandise will be 9403.20.0086, Harmonized Tariff Schedule of
the United States, (HTSUS), which provides for “Other furniture and parts thereof: Other metal furniture:
Other: Counters, lockers, racks, display cases, shelves, partitions and similar fixtures: Other.” The rate of
duty will be free.
The binding ruling request also seeks confirmation if the subject merchandise is subject to Section 232 tariffs
based on the cost of the recycled aluminum. Subheading 9403.20.00 HTSUS, is identified in U.S. Note 19(k)
to Subchapter III, Chapter 99 of the tariff schedule.
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 9403.20.0086, 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 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 9403.20.0086, 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 from all countries,
including China, 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 9403.20.0086, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 9401.79.0025, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report Chapter 99 subheading 9903.88.03 in
addition to subheading 9403.20.0086, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively.
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