CLA-2-73:OT:RR:NC:N5:121
Irene Lew
Gatco Inc.
1550 Factor Avenue
San Leandro, CA 94577
RE: The tariff classification of a steel floor standing toilet paper holder from Taiwan
Dear Ms. Lew:
In your letter dated August 27, 2025, you requested a tariff classification ruling.
The article under consideration is described as a Freestanding Floor Toilet Paper Holder, product series 1437.
Item #1437C has a chrome finish and Item #1437SN has a satin nickel finish. This toilet tissue holder
consists of a weighted circular base that measures 6.25 inches in diameter, a vertical steel rod that measures
22.25 inches tall, and a horizontal steel rod at the top that measures 6.88 inches long. It weighs 3.90 lbs. and
holds 1 toilet paper roll at a time. The toilet paper holder is made of low carbon recyclable hollow steel
tubing and a steel stamped base cover, a zinc knob, and resin/sand provides the weight to the base. You state
its primary use is residential; however, it can also be used in commercial settings.
The Freestanding Floor Toilet Paper Holder is composed of different components (steel tubing and base
cover, zinc knob, and resin/sand used for weight) and is considered a composite good. The Explanatory Notes
to the Harmonized Tariff Schedule of the United States (HTSUS), GRI 3(b) (VIII), state that the factor which
determines essential character will vary between different kinds of goods. It may, for example, be determined
by the nature of the materials or components, its bulk, quantity, weight or value, or by the role of a
constituent material in relation to the use of the goods. When the essential character of a composite good can
be determined, the whole product is classified as if it consists only of the material or component that imparts
the essential character to the composite good. We note that the steel tubing and steel base cover create the
structure of the toilet paper holder and that those steel components predominate by value. Consequently, we
find that the steel components impart the essential character.
The applicable subheading for the Freestanding Floor Toilet Paper Holder, product series 1437, Item #1437C
and #1437SN will be 7324.90.0000, HTSUS, which provides for Sanitary ware and parts thereof, of iron or
steel: Other, including parts. The rate of duty will be free.
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter
99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as
products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 percent upon
the value of the steel content. At the time of entry, you must report the Chapter 99 heading applicable to your
product classification, i.e. 9903.81.90, in addition to subheading 7324.90.0000, HTSUS. Derivative iron or
steel products processed in another country from steel articles melted and poured in the United States,
provided for in heading 9903.81.92, are not subject to the additional ad valorem duties.
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 Taiwan will be
subject to an additional ad valorem rate of duty of 20 percent. For products covered by heading 9903.81.90
this additional duty applies to the non-steel content of the merchandise. At the time of entry, you must report
the Chapter 99 heading applicable to your product classification, i.e. 9903.02.60, in addition to subheading
7324.90.0000, 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 Jennifer Jameson at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division