CLA-2-94:OT:RR:NC:N5:433
Cathy Yu
Jakks Pacific
21749 Baker Pkwy
Walnut, CA 91789
RE: The tariff classification of a seat from China
Dear Ms. Yu:
In your letter dated August 28, 2025, you requested a tariff classification ruling. A sample, illustrative
literature, and a product description were provided for review.
Item 612981-V1, the “Quicksilver Low Beach Chair,” is a folding outdoor seat constructed of a powder
coated steel frame and 100% polyester textile seating and backing material. The seat armrests and headrest
have foam cushions encased in removeable 100% polyester textile backing material with Velcro straps.
Seating is provided for a single individual. The seat dimensions approximate 20.1” in width, 23.2” in depth,
23.4” in height, and has a weight capacity of 225 lbs. The seat folds and contains a textile shoulder strap for
portability.
The binding ruling request seeks classification of the subject merchandise in subheading 9401.80.6030,
Harmonized Tariff Schedule of the United States, (HTSUS). We disagree
The Harmonized Commodity Description and Coding System Explanatory Notes (“ENs”) constitute the
official interpretation of the Harmonized System at the international level.
EN III to General Rule of Interpretation (GRI) 1 states, “the second part of this Rule provides that
classification shall be determined:
(a) according to the terms of the headings and any relative Section or Chapter Notes, and
(b) where appropriate, provided the headings or Notes do not otherwise require, according to the
provisions of Rule 2, 3, 4, and 5.”
Chapter 94, subheading 9401.79.00 provides for “Other seats, with metal frames: Other: Outdoor: With
textile covered cushions or textile seating or backing material.” The “Quicksilver Low Beach Chair” is a
metal frame unupholstered seat with textile seating or backing material; the terms of the heading and the
article description are satisfied.
The applicable subheading for the subject merchandise will be 9401.79.0015, HTSUS, which provides for
“Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Other
seats, with metal frames: Other: Other: Outdoor: With textile covered cushions or textile seating or
backing material: Other.” The rate of duty will be free.
Trade Remedy:
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 9401.79.0015, HTSUS, listed above.
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. 9903.81.91, in addition to subheading 9401.79.0015, 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 China, Hong
Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. Your product falls
within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to
your product classification, i.e. 9903.01.25 or exclusion subheading, in addition to subheading 9401.79.0015,
HTSUS, listed above.
Products of China classified under subheading 9401.79.0015, HTSUS, unless specifically excluded, are
subject to the additional 25 percent ad valorem rate of duty. At the time of importation, you must report the
Chapter 99 subheading, i.e., 9903.88.04, in addition to subheading 9401.79.0015, HTSUS, listed above. See
U.S. Note 20 to Subchapter III, Chapter 99, HTSUS.
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 Section 301 trade remedy, 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/remedies/301-certain-products-china, 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 Dharmendra Lilia at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division