CLA-2-94:OT:RR:NC:N2:349
Ms. Edna Arreola
Ikano Industry
Camino A Los Nuncios 100 Colonia Otra No Especificada En El Catalogo
Ramos Arizpe, Coahuila de Zaragoza 25946
Mexico
RE: The tariff classification of a pocket spring unit for a mattress from Mexico
Dear Ms. Arreola:
In your letter dated August 21, 2025, you requested a tariff classification ruling on a pocket spring unit. In
lieu of samples, diagrams and photographs were provided.
Item #2281593, described as “VALEVAG,” is a pocket spring unit intended for use as the core support
component in a pocket coil mattress. The spring coils, each measuring approximately 170 mm in height and
63 mm in diameter, are made of steel wire of a diameter ranging from 1.7 mm to 1.9 mm. Each spring coil is
individually sealed in a nonwoven barrel shaped pocket composed of 100 percent polypropylene spunbonded
fabric to form a spring coil pocket. Each spring unit is held together by gluing the barrel shaped fabric
pockets to one another, forming a unified rectangular mattress core unit arranged in a grid format. The units
are assembled in Mexico and will be produced in the following sizes:
Item Item Name Dimensions (approximate W x L x D) Number of springs
1 VALEVAG TW 965mm x 1892mm x 170mm 15 x 30 = 450
2 VALEVAG FU/DBL 1346mm x1892mm x 170mm 21 × 30 = 630
3 VALEVAG QN NA/AU 1524mm x 2019mm x 170mm 24 × 32 = 768
4 VALEVAG KG NA 1930mm x 2019mm x 170mm 30 × 32 = 960
You suggest that the barrel-shaped pocket spring unit is classified under subheading 9404.90.1000,
Harmonized Tariff Schedule of the United States (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: Mattress supports. We disagree. Mattress supports are items such as box springs that are
designed to be placed under a mattress for support. The “VALEVAG” support system is a barrel-shaped
pocket spring unit used in the manufacture of the mattress, rather than the mattress support; therefore,
subheading 9404.90.1000, HTSUS, is not appropriate.
The applicable subheading for the barrel-shaped pocket spring unit, item# 2281593, described as
“VALEVAG,” will be subheading 9404.29.9013, 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: Mattresses: Of other materials: Other: Uncovered innerspring units: Of a width exceeding 91
cm, of a length exceeding 184 cm, and of a depth exceeding 8 cm.” The general rate of duty will be 6
percent ad valorem.
Products of Mexico as provided by heading 9903.01.01 in Section XXII, Chapter 99, Subchapter III, U.S.
Note 2(a), HTSUS, other than products classifiable under headings 9903.01.02, 9903.01.03, 9903.01.04, and
9903.01.05, HTSUS, will be subject to an additional 25 percent ad valorem rate of duty. At the time of entry,
you must report the applicable Chapter 99 heading, i.e. 9903.01.01, in addition to subheading 9404.29.9013,
HTSUS, listed above. Articles that are entered free of duty under the terms of general note 11 to the HTSUS
(U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set forth in subchapter XXIII of
Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be subject to the additional ad valorem
duties provided for in heading 9903.01.01. If your product is entered duty free as originating under the
USMCA, you must report heading 9903.01.04, HTSUS, in addition to subheading 9404.29.9013, HTSUS,
listed.
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 Mexico are not
subject to reciprocal tariffs. At the time of entry, you must report the Chapter 99 heading applicable to your
product classification, i.e. 9903.01.27, in addition to subheading 9404.29.9013, 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 Kim Wachtel at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division