CLA-2-39:OT:RR:NC:N4:415
Jiwon Kwon
CUSAN Customs Service Incorporation
Number 309, 35, Magokjungang 2-ro, Gangseo-gu
Seoul, 07806
South Korea
RE: The tariff classification of five air mattresses from South Korea.
Dear Ms. Kwon:
In your letter dated July 30, 2025, you requested a tariff classification ruling on behalf of your client,
ANSSil.
Images were provided in lieu of samples.
This request consists of five products for consideration. They are all described in your submission as air
mattresses. Each mattress is composed of an air support system equipped with high-tensile strings (threads),
a high-resilience foam topper, outer fabrics, and is operated by an electronic controller. If the mattress is
purchased without the electronic controller, it can also be inflated using a standard household air pump. You
indicate that while the cover materials and designs vary, all five models share the same core structure which
is called the Air String Support system. It is made from thermoplastic polyurethane (TPU) and polyvinyl
chloride (PVC) plastic materials and provides these mattresses with their cushioning and support. We note
that you state that without air, these products remain flat and highly compressible, rendering them incapable
of supporting body weight or serving as a functional sleeping surface.
The first mattress is described as the “Flat Grid Plus.” It features a Euro-top design with a three-layer
construction: a top cover layer made from cooling, flame-retardant jacquard fabric, a comfort layer of
high-resilience polyurethane foam, and a core layer consisting of the Air String inflation structure. The cover
is non-removable.
The second mattress is described as the “Healing No.” It has a tight top surface with an outer fabric of
Tencel Jacquard. The cover is non-removable.
The third mattress is described as the “All Care.” It has a smooth top surface and uses standard jacquard
fabric. The cover is non-removable.
The fourth mattress is described as the “Snow Falls.” It features a smooth top design and an expanded height
for added cushioning. This mattress uses cooling jacquard fabric and has a removable cover for easier
maintenance.
The fifth mattress is described as the “Smart i5 (sensor option).” It is a smooth top mattress featuring a
removable cooling jacquard cover. This model can be used with the standard manual electronic controller,
but when equipped with the optional sensor pad, it offers automatic real-time firmness adjustment based on
sleep posture and pressure data.
We agree that the applicable subheading for these five mattresses, “Flat Grid Plus,” “Healing No.,” “All
Care,” “Snow Falls,” and “Smart i5 (sensor option),” will be 3926.90.7500, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for “[o]ther articles of plastics and articles of other materials of
headings 3901 to 3914: [o]ther: [p]neumatic mattresses and other inflatable articles, not elsewhere specified
or included.” The column one, general rate of duty is 4.2 percent ad valorem.
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 of South Korea
will be subject to an additional ad valorem rate of duty of 15 percent. At the time of entry, you must report
the Chapter 99 heading applicable to your product classification, i.e., 9903.02.56, in addition to subheading
3926.90.7500, HTSUS, listed above.
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/current.
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 CBP Regulations (19 CFR 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, contact
National Import Specialist Kristopher Burton at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division