CLA-2-94:OT:RR:NC:N2:349
Ms. Edna Arreola
Ikano Industry Mexico S.A. de C.V.
Camino A Los Nuncios, 100 Colonia Otra No Especificada En El Catalogo
Ramos Arizpe, Coahuila de Zaragoza 25946
Mexico
RE: The tariff classification of an uncovered foam mattress from Mexico
Dear Ms. Arreola:
In your letter dated September 3, 2025, you requested a tariff classification ruling for a mattress core. In lieu
of a sample, a technical drawing of the product with specification details was provided.
The subject item is the structural core of an IKEA® brand mattress, product name “ASVANG.” The
component is made of polyurethane cellular foam and features egg crate depressions on the top surface with a
flat bottom surface. The foam core is not covered at time of importation. You state that the textile cover will
be applied later in the assembly process. The foam mattress core is manufactured in Mexico and will be
produced and imported into the United States in the following sizes:
Item Item Name Dimensions (approximate W x L x D) Sizes
1 ASVANG 96.5 cm x 189.2 cm x 12 cm Twin
2 ASVANG 134.6 cm x 189.2 cm x 12 cm Full
3 ASVANG 152.4 cm x 201.9 cm x 12 cm Queen
4 ASVANG 193 cm x 201.9 cm x 12 cm King
You suggest that the foam core for the mattress is classified under subheading 3921.13.1950, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for other plates, sheets, film, foil and strip, of
polyurethane plastics, cellular, combined with a single textile material, other. We disagree. Legal Note 10 to
Chapter 39, HTSUS, states, “In headings 3920 and 3921, the expression “plates, sheets, film, foil and strip”
applies only to plates, sheets, film, foil and strip (other than those of chapter 54) and to blocks of regular
geometric shape, whether or not printed or otherwise surface-worked, uncut or cut into rectangles (including
squares) but not further worked (even if when so cut they become articles ready for use).” The polyurethane
cellular plastic foam core mattress incorporates a top surface incorporating an egg crate design and a flat
bottom surface. Therefore, it is not considered to be a block of regular geometric shape and is precluded
from classification in subheading 3921.13.1950, HTSUS.
The applicable subheading for the foam core for the mattress “ASVANG,” will be 9404.21.0013, 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 cellular rubber or plastics,
whether or not covered: Of a width, exceeding 91 cm, of a length exceeding 184 cm, and a depth exceeding
8 cm.” The rate of duty will be 3 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 9404.21.0013,
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 9404.21.0013, 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 9404.21.0013, HTSUS, listed above.
The merchandise in question may be subject to antidumping duties and/or countervailing duties (“AD/CVD”)
for all types of youth and adult mattresses from Mexico (A-201-859). Written decisions regarding the scope
of AD/CVD orders are issued by the Enforcement and Compliance office in the International Trade
Administration of the Department of Commerce (ITA) and are separate from tariff classification and origin
rulings issued by Customs and Border Protection (CBP). You can contact them at
https://trade.gov/enforcement/ (click on “Contact Us”). For your information, you can view a list of current
AD/CVD cases at the Department of Commerce ITA website at
https://www.trade.gov/data-visualization/adcvd-proceedings, and you can search AD/CVD deposit and
liquidation messages using CBP’s AD/CVD Search tool at https://aceservices.cbp.dhs.gov/adcvdweb.
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
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division