OT:RR:NC:N2:349
TARIFF NO: 9404.40.9005; 9404.40.9022; 9404.40.1000; 9404.90.1060; 9404.90.2060; 9903.01.24;
9903.01.84; 9903.01.25; 9903.02.26; 9903.88.15
Mr. Matt New
Green Worldwide Shipping LLC
3131 S Vaugn Way, Suite 134
Aurora, CO 80014
RE: The tariff classification, country of origin, and eligibility under the United States-Mexico-Canada
Agreement (USMCA) for comforters and pillows; 19 CFR 102.21(c)(2); tariff shift
Dear Mr. New:
This is in reply to your letter dated August 1, 2025, submitted on behalf of your client, Down-Lite
International Inc., requesting a ruling on the classification, country of origin and status under the United
States-Mexico-Canada Agreement (USMCA) for certain comforters and pillows, which will be imported into
the United States. In lieu of the samples, photographs were provided with your request.
FACTS:
The item identified as “Comforter #1,” SKU # CO10107, is a baffled box comforter made with an outer shell
of 100 percent cotton woven fabric that is bleached. The comforter is stuffed with goose or duck down and
has baffle walls made of 100 percent polyester woven scrim to keep the down from shifting. The shell fabric
is neither dyed nor printed. The completed comforter contains no embroidery, lace, braid, edging, trimming,
or applique work, but does feature 3.18 mm self-fabric piping sewn on the four sides of the comforter
between the front and back panels. The comforter will be offered in different sizes: Twin 68 x 88 inches,
Queen 90 x 96 inches, and King 108 x 96 inches and is available in the following SKUs and size/density fill
weight:
Name SKU# Size/Density (fill weight)
Comforter #1 CO10107-0001 Twin Light Weight (21 OZ)
Comforter #1 CO10107-0002 Queen Light Weight (30 OZ)
Comforter #1 CO10107-0003 King Light Weight (36 OZ)
Comforter #1 CO10107-0004 Twin Medium Weight (28 OZ)
Comforter #1 CO10107-0005 Queen Medium Weight (40 OZ)
Comforter #1 CO10107-0006 King Medium Weight (48 OZ)
Comforter #1 CO10107-0007 Twin Heavy Weight (35 OZ)
Comforter #1 CO10107-0008 Queen Heavy Weight (50 OZ)
Comforter #1 CO10107-0009 King Heavy Weight (60 OZ)
The item identified as “Comforter #2,” SKU # CO50034, is a quilted comforter made with an outer shell of
100 percent polyester woven fabric. The fabric making up the face and back panels is bleached and dyed but
not printed. The comforter is stuffed with polyester fiberfill. The three layers are quilted together in a double
box pattern. The completed comforter contains no embroidery, lace, braid, edging, trimming, or applique
work, but does feature 3.18 mm self-fabric piping sewn on the four sides of the comforter between the front
and back panels. The comforter will be offered in four different colors and 2 sizes: Queen 90 x 98 inches and
King 108 x 96 inches. The comforter is available in the following SKUs and size/density fill weight:
Name SKU# Size/Density (fill weight)
Comforter #2 CO50034-0001 Queen Weight (54 OZ)
Comforter #2 CO50034-0002 King Weight (65 OZ)
The item identified as “Comforter #3A,” SKU # CO40080, is a baffled box comforter made with an outer
shell of 100 percent cotton woven fabric. The comforter is stuffed with polyester fiberfill and has baffle
walls made of 100 percent polyester woven scrim to keep the polyester filling from shifting. The fabric
making up the face and back panels is bleached white. The fabric is neither dyed nor printed. The comforter
contains no embroidery, lace, braid, edging, trimming, or applique work, but does feature 3.18 mm self-fabric
piping sewn on the four sides of the comforter between the front and back panels. The comforter will be
offered in different sizes: Twin 74 x 94 inches, Queen 94 x 100 inches and King 112 x 100 inches. The
comforter is available in the following SKUs and size/density fill weight:
Name SKU# Size/Density (fill weight)
Comforter #3A CO40080-0001 Twin Weight (45 OZ)
Comforter #3A CO40080-0002 Queen Weight (55 OZ)
Comforter #3A CO40080-0003 King Weight (65 OZ)
The item identified as “Comforter #3B,” SKU # CO40024, is a baffled box comforter made with an outer
shell of 100 percent cotton woven fabric. The comforter is stuffed with polyester fiberfill and has baffle
walls made of 100 percent polyester woven scrim to keep the polyester filling from shifting. The fabric
making up the face and back panels is bleached white. The fabric is neither dyed nor printed. The comforter
contains no embroidery, lace, braid, edging, trimming, or applique work, but does feature 3.18 mm self-fabric
piping sewn on the four sides of the comforter between the front and back panels. The comforter will be
offered in different sizes: Twin 74 x 92 inches, Queen 94 x 98 inches and King 112 x 98 inches. The
comforter is available in the following SKUs and size/density fill weight:
Name SKU# Size/Density (fill Weight)
Comforter #3B CO40024-0010 Twin Light Weight (25 OZ)
Comforter #3B CO40024-0011 Queen Light Weight (33 OZ)
Comforter #3B CO40024-0012 King Light Weight (44 OZ)
Comforter #3B CO40024-0004 Twin Medium Weight (34 OZ)
Comforter #3B CO40024-0005 Queen Medium Weight (44 OZ)
Comforter #3B CO40024-0006 King Medium Weight (52 OZ)
Comforter #3B CO40024-0007 Twin Heavy Weight (44 OZ)
Comforter #3B CO40024-0008 Queen Heavy Weight (55 OZ)
Comforter #3B CO40024-0009 King Heavy Weight (66 OZ)
The item identified as a “Pillow #1,” SKU # PI10058, is a stuffed bed pillow made with an outer shell of 100
percent cotton woven fabric. The pillow is stuffed with goose or duck down. The face and back panel fabric
is bleached white. The fabric is neither dyed nor printed. The pillow contains no embroidery, lace, braid,
edging, trimming, or applique work, but does feature 3.18 mm self-fabric piping sewn on the four sides of the
pillow between the front and back panels. The pillow will be imported in Jumbo size, 20 x 28 inches, and
King size, 20 x 36 inches. The pillow is available in the following SKUs and size/density fill weight:
Name SKU# Size/Density (fill Weight)
Pillow #1 PI10058-0001 Jumbo, Soft (20 OZ)
Pillow #1 PI10058-0002 King, Soft (25 OZ)
Pillow #1 PI10058-0003 Jumbo, Medium (24 OZ)
Pillow #1 PI10058-0004 King, Medium (31 OZ)
Pillow #1 PI10058-0005 Jumbo, Firm (28 OZ)
Pillow #1 PI10058-0006 King, Firm (36 OZ)
The item identified as a “Pillow #2,” SKU # PI50149-0001, is a stuffed bed pillow made with an outer shell
of 100 percent polyester woven fabric. The pillow is stuffed with loose polyester fiberfill. The face and back
panel fabric is bleached. The fabric is neither dyed nor printed. The pillow contains no embroidery, lace,
braid, edging, trimming, piping or applique work. You state the pillow has knife edges along all its edges.
The pillow will be offered in Jumbo size, measuring 20 x 28 inches, with a density (fill weight) of 36 ounces.
The manufacturing operations for “Comforter #1,” SKU # CO10107, are as follows:
China
Cotton fabric for the comforter shell is woven and bleached.
Polyester scrim, piping cord and polyester thread are produced.
Fabrics and piping are cut, sewn, and assembled into an unfilled baffled box comforter shell.
Down is sourced from geese and ducks.
Down, polyester thread, and comforter shell are exported to Canada or Mexico.
Canada or Mexico
The comforter shell is filled with down.
Comforter is sewn closed.
The finished comforter is vacuum sealed, packaged and exported to the United States.
The manufacturing operations for “Comforter #2,” SKU # CO50034, are as follows:
China
Polyester fabric for the comforter shell is woven, bleached and dyed.
Piping and polyester thread are produced.
Fabric and piping are cut, sewn, and assembled into an unfilled comforter shell.
Unfilled comforter shell and polyester thread are exported to Canada or Mexico.
Thailand
Polyester fiberfill is produced.
Polyester fiberfill is exported to Canada or Mexico.
Canada or Mexico
The comforter shell is filled with polyester filling.
Comforter is quilted and sewn closed.
The finished quilted comforter is vacuum sealed, packaged and exported to the United States.
The manufacturing operations for “Comforter #3A,” SKU # CO40080, and “Comforter #3B,” SKU #
CO40024, are as follows:
China (#3A) or India (#3B)
Cotton fabric for the comforter shell is woven and bleached.
Polyester scrim, piping and polyester thread are produced.
Fabrics and piping are cut, sewn, and assembled into an unfilled baffled box comforter shell.
Unfilled comforter shell and polyester thread are exported to Canada or Mexico.
Thailand
Polyester fiberfill is produced.
Polyester fiberfill is exported to Canada or Mexico.
Canada or Mexico
The comforter shell is filled with polyester fiberfill.
Comforter is sewn closed.
The finished quilted comforter is vacuum sealed, packaged and exported to the United States.
The manufacturing operations for “Pillow #1,” SKU # PI10058, are as follows:
China
Cotton fabric for the pillow shell is woven and bleached.
Self-fabric piping and polyester thread are produced.
Fabric and piping are cut, sewn and assembled into an unfilled pillow shell.
Down is sourced from geese and ducks.
Pillow shell, down, and polyester thread are exported to Canada or Mexico.
Canada/Mexico
The pillow shell is filled with down and sewn closed.
The finished bed pillow is vacuum sealed, packaged and exported to the United States.
The manufacturing operations for “Pillow #2,” SKU # PI50149-0001, are as follows:
China
Polyester fabric for the pillow shell is woven and bleached.
Polyester thread is produced.
Fabric is cut, sewn and assembled into an unfilled pillow shell.
Polyester thread and assembled unfilled pillow shell are exported to Canada or Mexico.
India
Polyester fiberfill is produced.
Polyester fiberfill is exported to Mexico or Canada.
Canada/Mexico
The pillow shell is filled with polyester filling and sewn closed.
The finished bed pillow is vacuum sealed, packaged, and exported to the United States.
ISSUE:
What are the classification, country of origin and status under USMCA of the subject merchandise?
CLASSIFICATION:
You suggest a tariff classification of “Comforter #1,” SKU # CO10107, in subheading 9404.40.9005,
Harmonized Tariff Schedule of the United States (HTSUS). We agree.
In Pillowtex Corporation v. United States, 983 F. Supp. 188, Slip Op. 97-146, dated October 28, 1997, aff’d,
Slip Op. 98-1227 (Fed. Cir. March 16, 1999), the United States Court of Appeals for the Federal Circuit
(USCAFC) determined that comforters made of 100 percent cotton outer shells stuffed with white duck down
were classified pursuant to the General Rules of Interpretation (GRIs) of the HTSUS, GRI 3(b), with the
“essential character” of the comforters being their insulating quality, which was imparted by their down
filling, and not the cotton shells.
In N324666 (4/5/22), N279885 (10/24/16) and N041681 (10/29/08), concerning the classification of
comforters, duvets and quilts, and consistent with the SCAFC, Pillowtex Corporation, this office determined
that the essential character was imparted by the down filling and not the outer shell.
The applicable subheading for “Comforter #1,” SKU # CO10107, will be subheading 9404.40.9005, HTSUS,
which provides for “Mattress supports; articles of bedding and similar furnishing (for example, mattresses,
quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed or internally fitted with any
material or of cellular rubber or plastics, whether or not covered: Quilts, bedspreads, eiderdowns and duvets
(comforters): Other: With outer shell of cotton.” The general rate of duty will be 12.8 percent ad valorem.
You suggest a tariff classification for “Comforter #2,” SKU # CO50034, in subheading 9404.40.9022,
HTSUS. We agree. The applicable subheading for “Comforter #2,” SKU # CO50034, will be subheading
9404.40.9022, HTSUS, which provides for “Mattress supports; articles of bedding and similar furnishing (for
example, mattresses, quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed or
internally fitted with any material or of cellular rubber or plastics, whether or not covered: Quilts,
bedspreads, eiderdowns and duvets (comforters): Other: With outer shell of man-made fibers.” The general
rate of duty will be 12.8 percent ad valorem.
You suggest a tariff classification for “Comforter #3A,” SKU # CO40080, and “Comforter #3B,” SKU
#CO40024, in subheading 9404.40.1000, HTSUS. We agree. The applicable subheading for “Comforter
#3A,” SKU # CO40080, and “Comforter #3B,” SKU #CO40024, will be subheading 9404.40.1000, HTSUS,
which provides for “Mattress supports; articles of bedding and similar furnishing (for example, mattresses,
quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed or internally fitted with any
material or of cellular rubber or plastics, whether or not covered: Quilts, bedspreads, eiderdowns and duvets
(comforters): Of cotton, not containing any embroidery, lace, braid, edging, trimming, piping exceeding 6.35
mm or applique work .” The general rate of duty will be 4.4 percent ad valorem.
You suggest a tariff classification for “Pillow #1,” SKU # PI10058, in subheading 9404.90.1060, HTSUS.
We agree. The applicable subheading for “Pillow #1,” SKU # PI10058, will be subheading 9404.90.1060,
HTSUS, which provides for “Mattress supports; articles of bedding and similar furnishing (for example,
mattresses, quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed or internally fitted
with any material or of cellular rubber or plastics, whether or not covered: Other: Pillows, cushions and
similar furnishings: Of cotton: Bed pillows (with outer covering of cotton), of a kind described in statistical
note 5 to this chapter: Other fill.” The general rate of duty will be 5.3 percent ad valorem.
You suggest a tariff classification for “Pillow #2,” SKU # PI50149-0001, in subheading 9404.90.2060,
HTSUS. We agree. The applicable subheading for “Pillow #2,” SKU # PI50149-0001, will be subheading
9404.90.2060, HTSUS, which provides for “Mattress supports; articles of bedding and similar furnishing (for
example, mattresses, quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed or
internally fitted with any material or of cellular rubber or plastics, whether or not covered: Other: Pillows,
cushions and similar furnishings: Other: Bed pillows, of a kind described in statistical note 5 to this chapter:
Other fill.” The general rate of duty will be 6 percent ad valorem.
COUNTRY OF ORIGIN - LAW AND ANALYSIS:
Section 334 of the Uruguay Round Agreements Act (“URAA”) (codified at 19 U.S.C. 3592), enacted on
December 8, 1994, provides the rules of origin for textiles and apparel products for purposes of the customs
laws and the administration of quantitative restrictions, unless otherwise provided by the statute, entered, or
withdrawn from warehouse, for consumption on or after July 1, 1996. Section 3592 has been described as
Congress’s expression of substantial transformation as it relates to textile and apparel products. Section
102.21 of the Code of Federal Regulations (19 CFR 102.21), implements the URAA. The country of origin of
a textile or apparel product shall be determined by the sequential application of the general rules set forth in
paragraphs (c)(1) through (5) of section 102.21. See 19 CFR 102.21(c).
Paragraph (c)(1) states, “The country of origin of a textile or apparel product is the single country, territory,
or insular possession in which the good was wholly obtained or produced.” As the subject merchandise is not
wholly obtained or produced in a single country, territory or insular possession, paragraph (c)(1) of Section
102.21 is inapplicable.
Paragraph (c)(2) states, “Where the country of origin of a textile or apparel product cannot be determined
under paragraph (c)(1) of this section, the country of origin of the good is the single country, territory, or
insular possession in which each of the foreign materials incorporated in that good underwent an applicable
change in tariff classification, and/or met any other requirement, specified for the good in paragraph (e) of
this section:”
We note that the subject comforters are classified in subheadings 9404.40.10, HTSUS and 9404.40.90,
HTSUS. Prior to 2022, the corresponding HTSUS classification for subheading 9404.40.10, HTSUS, was
subheading 9404.90.80, HTSUS, and the corresponding HTSUS classification for subheading 9404.40.90,
HTSUS, was subheading 9404.90.85, HTSUS. Paragraph (e)(2) has not been updated to the current
subheadings; therefore, we follow the rule corresponding to the prior subheading, in the analysis below. See
New York Ruling Letter N338830.
Paragraph (e), in pertinent part, states,
The following rules shall apply for purposes of determining the country of origin of a textile or
apparel product under paragraph (c)(2) of this section:
HTSUS Tariff shift and/or other requirements
9404.90 Except for goods of subheading 9404.90 provided for in paragraph (e)(2) of
this section, the country of origin of a good classifiable under subheading
9404.90 is the country, territory, or insular possession in which the fabric
comprising the good was formed by a fabric-making process.
The “fabric-making process” is defined in 19 CFR 102.21(b)(2) as “any manufacturing operation that begins
with polymers, fibers, filaments (including strips), yarns, twine, cordage, rope, or fabric strips and results in a
textile fabric.”
Based on the information provided in your letter, “Comforter 1,” “Comforter #3A,” “Comforter #3B,”
“Pillow #1” and “Pillow #2” are not included in the paragraph (e)(2) exception to the above tariff shift rule.
Therefore, as the fabrics comprising “Comforter #1,” “Comforter #3A,” “Pillow #1” and “Pillow #2” are
formed by the fabric-making process in a single country, that is China, country of origin is conferred in
China. As the fabric comprising “Comforter #3B” is formed by the fabric-making process in a single
country, that is India, country of origin is conferred in India.
“Comforter #2” is included in the paragraph (e)(2) exception and, therefore, we apply paragraph (e)(2)(i),
which states:
(i) The country of origin of the good is the country, territory, or insular possession in which the fabric
comprising the good was both dyed and printed when accompanied by two or more of the following
finishing operations: bleaching, shrinking, fulling, napping, decating, permanent stiffening,
weighting, permanent embossing, or moireing:
Since the fabric comprising “Comforter #2” is bleached and dyed, but not printed, and does not undergo two
or more of the aforementioned operations, the country of origin cannot be based on (e)(2)(i), above.
Paragraph (e)(2)(ii) states:
(ii) If the country of origin cannot be determined under paragraph (e)(2)(i) of this section, except for
goods of HTSUS subheading 6117.10 that are knit to shape or consist of two or more component
parts, the country of origin is the country, territory, or insular possession in which the fabric
comprising the good was formed by a fabric-making process;
Since “Comforter #2” is comprised of fabric formed by a fabric-making process in a single country, that is
China, country of origin is conferred in China.
USMCA ELIGIBILITY:
The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30,
2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the
USMCA Implementation Act. General Note (“GN”) 11 of the HTSUS implements the USMCA. GN 11(b)
sets forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN
11(b) states, in relevant part:
For the purposes of this note, a good imported into the customs territory of the United States from the
territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential
tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the
tariff schedule as a “good originating in the territory of a USMCA country” only if--
(i) the good is a good wholly obtained or produced entirely in the territory of one or more
USMCA countries;
(ii) the good is a good produced entirely in the territory of one or more USMCA countries,
exclusively from originating materials;
(iii) the good is a good produced entirely in the territory of one or more USMCA countries
using non originating materials, if the good satisfies all applicable requirements set forth in
this note (including the provisions of subdivision (o))
Since the comforters and pillows contain non-originating materials, they are not considered to be a good
wholly obtained or produced entirely in a USMCA country under GN 11(b)(i), nor are the products produced
exclusively from originating materials per GN 11(b)(ii). Thus, we must determine whether the product
qualifies under GN 11(b)(iii). The comforter and pillows are classified under subheading 9404.90, HTSUS.
The applicable rule of origin for goods classified under subheading 9404.90, HTSUS, GN 11(o)/ 94.7,
HTSUS, provides “[a] change to subheading 9404.90 from any other chapter, except from headings 5007,
5111 through 5113, 5208 through 5212, 5310 through 5311, 5407 through 5408 or 5512 through 5516.
Based on the facts provided, the goods described above qualify for USMCA preferential tariff treatment,
because they will meet the requirements of General Note 11(b)(iii) since all components and materials
undergo the prescribed tariff shift. The goods will, therefore, be entitled to a free rate of duty under the
USMCA upon compliance with all applicable laws, regulations, and agreements.
HOLDING:
The tariff classification for SKU # CO10107 (“Comforter #1”) is subheading 9404.40.9005, HTSUS. The
country of origin is China pursuant to 19 CFR 102.21(c)(2).
The tariff classification for SKU #CO50034 (“Comforter #2”) is subheading 9404.40.9022, HTSUS. The
country of origin is China pursuant to 19 CFR 102.21(c)(2).
The tariff classification for SKU#CO40080, (“Comforter #3A”) is subheading 9404.40.1000, HTSUS. The
country of origin is China pursuant to 19 CFR 102.21(c)(2).
The tariff classification for SKU #CO40024 (“Comforter #3B”) is subheading 9404.40.1000, HTSUS. The
country of origin is India pursuant to 19 CFR 102.21(c)(2).
The tariff classification for SKU #PI10058, (“Pillow #1”) is subheading 9404.90.1060, HTSUS. The country
of origin is China pursuant to 19 CFR 102.21(c)(2).
The tariff classification for SKU #PI50149-0001 (“Pillow #2”) is subheading 9404.90.2060, HTSUS. The
country of origin is China pursuant to 19 CFR 102.21(c)(2).
The comforters and pillows, described above, qualify for USMCA upon compliance with all applicable laws,
regulations, and agreements.
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 subheadings 9404.40.9005, 9404.40.9022, 9404.40.1000, 9404.90.1060 and 9404.90.2060, HTSUS, listed
above.
Effective August 27, 2025, Executive Order 14339 imposed additional duties on products from India. At this
time, products of India provided by heading 9903.01.84, except for products described in headings
9903.01.85 – 9903.01.89, will be subject to an additional ad valorem rate of duty of 25 percent. At the time
of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.84, in
addition to subheading 9404.40.1000, 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 of China, Hong
Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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 subheadings 9404.40.9005, 9404.40.9022, 9404.40.1000, 9404.90.1060 and 9404.90.2060, 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 of India will be
subject to an additional ad valorem rate of duty of 25 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.26, in addition to subheading
9404.40.1000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 9404.90.1060 and 9404.90.2060, HTSUS, unless specifically excluded, are subject to an
additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99
subheading, i.e., 9903.88.15, in addition to subheadings 9404.90.1060 and 9404.90.2060, 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 Kim Wachtel at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division