CLA-2-68:OT:RR:NC:N1:128
Mr. Chris Duncan
Stein Shostak Shostak Pollack & O'Hara LLP
445 S. Figueroa Street, Suite 2388
Los Angeles, CA 90071
RE: The tariff classification and status under the African Growth and Opportunity Act (AGOA) of an
artificial stone bathtub from South Africa.
Dear Mr. Duncan:
In your letter dated July 30, 2025, you requested a tariff classification ruling on behalf of your client, Zalkow
Discount Sourcing.
The merchandise under consideration is referred to as the Amelia Bath. A sample of the material used to
manufacture the Amelia Bath was submitted with your ruling request and forwarded to the Customs and
Border Protection Laboratory for analysis. This analysis has been completed.
From the information you provided, the Amelia Bath is a free-standing bathtub which measures
approximately 149 centimeters long by 71.5 centimeters wide by 51 centimeters high at its widest points. It
is designed to be installed in a bathroom and used for bathing.
Laboratory analysis has determined that the Amelia Bath is comprised of dolomite, as well as smaller
amounts of other minerals, uniformly agglomerated with a polymer.
The applicable subheading for the Amelia Bath will be 6810.99.0080, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for “Articles of cement, of concrete or of artificial stone, whether or
not reinforced: Other articles: Other: Other.” The general rate of duty will be Free.
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 South Africa
will be subject to an additional 30 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. 9903.02.55, in addition to subheading
6810.99.0080, HTSUS, listed above.
In your ruling request, you asked if the Amelia Bath qualified for free trade preference under the African
Growth and Opportunity Act (AGOA). However, there is no provision for AGOA preference under
subheading 6810.99.0080, HTSUS. Additionally, the AGOA program expired on September 30, 2025, and is
not currently in effect.
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 Nicole Sullivan at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division