CLA-2-94:OT:RR:NC:N5:433
Oscar Palacios
C.H. Robinson International
180 E. Ocean Blvd., Suite 700
Long Beach, CA 90008
RE: The tariff classification and country of origin of wooden furniture.
Dear Mr. Palacios:
In your letter dated August 25, 2025, you requested a binding tariff classification and country of origin ruling
on behalf of Ergomotion Inc. In lieu of samples, technical and illustrative literature, a product description,
and manufacturing processes were provided.
The item that is the subject of this ruling request is constructed of foreign and domestically sourced raw
materials. A description of the item immediately follows.
The “Bunkie Board Queen Bed Platform,” is a folding platform bedframe that will support a mattress without
the use of a box spring. The platform bedframe is constructed of plywood panels encased in 100% polyester
fabric and 100% polypropylene fabric. The platform bedframe will be 60” in length and 80” in width. The
platform bedframe will be made available to accommodate twin, twin XL, full, queen, king, and California
king mattresses.
The applicable subheading for the subject merchandise will be 9403.50.9045, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for “Other furniture and parts thereof: Wooden furniture of a
kind used in the bedroom: Other: Other: Beds: Other.” The rate of duty will be free.
Sourcing Scenario:
The ruling request outlines an operation wherein the bedframe wood components (plywood panels) will be
sourced in China. The bedframe components will be shipped and exported to Vietnam. In Vietnam, textile
components (rolls of polyester fabric, rolls of polypropylene materials, thread) will be locally sourced. In
Vietnam, the incomplete, unassembled, and unfinished furniture components will undergo manufacture.
Per the ruling submission, in Vietnam, (1) the Chinese plywood will be measured and cut to the size and
shapes of multiple panel slates using wood cutting machines that will coincide with twin, twin XL, full,
queen, king, and California king bedding dimensions, (2) the rolls of polyester textile fabrics will be
measured and cut to specific size and dimensions to create multiple fabric panels using fabric cutting
machines, (3) the rolls of polypropylene textile fabrics will be measured and cut to specific size and
dimensions to create multiple fabric panels using fabric cutting machines, (4) the textile fabric panels will be
sewn together using sewing machines, and (5) the plywood panels will be positioned and encased in the
textile fabrics panels with staples that are inserted around the perimeter using pneumatic air tools. In
Vietnam, the complete, platform bedframe will be inspected, packed, labeled, and then exported to the United
States. Photographs of these processes were provided.
Country of Origin:
When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,
Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a
substantial transformation will occur is whether an article emerges from a process with a new name,
character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v.
United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See
National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).
In the instant case, the Chinese components lose their identity during manufacture and undergo a substantial
transformation in Vietnam to become a platform bedframe, thereby, taking on a new name, character, and
use. In view of these facts, the country of origin for the platform bedframe will be Vietnam.
Trade Remedy:
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 Vietnam will be
subject to an additional ad valorem rate of duty of 20% percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.69, in addition to subheading
9403.50.9045, 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 Dharmendra Lilia at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division