CLA-2-87:OT:RR:NC:N2:201
Lucy Jones
FFORA
3724 24th Street, Suite 114
Long Island City, NY 11101
RE: The tariff classification of cupholder and mounting system used on wheelchairs from China
Dear Ms. Jones:
In your letter dated August 27, 2025, you requested a tariff classification ruling.
The items under consideration has been identified as plastic cupholders and the accompanying metal
attachment system designed exclusively for use with wheelchairs.
The cupholder, manufactured in China, is made of injection-molded plastic components that attach securely
to the frame of a wheelchair via a clamp or mounting bracket. From the information provided it is clear that
the proprietary mounting bracket is designed to be used with multiple FFORA adapted accessories, such as
cupholders, cellphone holders, etc. providing convenience and accessibility to the wheelchair user.
There are, in our opinion, three (3) questions at issue
1. The classification of the cupholder and mount when packaged for sale together.
2. The classification of the cupholder if imported separately, and finally
3. The classification of the mounting system if imported separately
The cupholder is primarily composed of durable, injection-molded ABS plastic with a small metal
component (less than 5% of overall weight.) The cupholder is not equipped to mount directly to any item.
The mount, manufactured in India, is made of a zinc alloy body with integrated magnetic interface and clamp
system that clamps securely to the wheelchair frame. You state that this accessory functions with the
cupholder, or other compatible items to attach magnetically for secure yet removable placement on a
wheelchair.
The applicable subheading for the FFORA cupholder and mounting system if imported together in retail
packaging will be 8714.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides
for “Parts and accessories of vehicles of headings 8711 to 8713: Of carriages for disabled persons.” The
general rate of duty will be Free.
The applicable subheading for the FFORA mounting system if imported in retail packaging will be
8714.20.0000, HTSUS, which provides for “Parts and accessories of vehicles of headings 8711 to 8713: Of
carriages for disabled persons.” The general rate of duty will be Free.
As the subject cupholder, when imported separately, would be considered an article of plastic, and as it is not
more specifically provided for elsewhere, the applicable subheading will be 3926.90.9989, HTSUS, which
provides for “Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Other:
Other.” The general rate of duty is 5.3 percent ad valorem.
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 subheading 3926.90.9989, 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 subheading 3926.90.9989, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 3926.90.9989, 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 subheading 3926.90.9989, 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 Matthew Sullivan at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division