CLA-2-73:OT:RR:NC:N4:422
Ms. Kristine Leigh
In Spades LLC DBA FÜZI
7475 Andover Way
Hudson, OH 44236
RE: The tariff classification of a dog bed from Vietnam
Dear Ms. Leigh:
In your letter dated September 11, 2025, you requested a tariff classification ruling. Photographs were
submitted along with your request.
The merchandise is referred to as the Up-Pup Platform Dog Bed. Each bed has a powder-coated steel tubular
frame, connecting powder-coated steel rods, adjustable powder-coated steel feet, and powder-coated steel
hardware accessories. The platform bed features square woven polyester textile mesh that is braced with
polyester bands for strength and attached to the steel frame. The steel platform bed is elevated several inches
above ground, is designed for dogs, and will be used in the home.
The bed is available in small (PS-BL-V2), medium (PM-BL-V2), large (PL-BL-V2), and extra-large
(PXL-BL). The small bed measures approximately 25.50 inches long by 16.70 inches wide by 8.75 inches
high and holds dogs up to 50 lbs. The medium bed measures approximately 31.75 inches long by 23.75
inches wide by 8.75 inches high and holds dogs up to 70 lbs. The large bed measures approximately 35.5
inches long by 38.25 inches wide by 8.75 inches high and holds dogs up to 110 lbs. The extra-large bed
measures approximately 44.75 inches long by 30.00 inches wide by 8.75 inches high and holds dogs up to
150 lbs.
The applicable subheading for the Up-Pup Platform Dog Bed (PS-BL-V2, PM-BL-V2, PL-BL-V2, and
PXL-BL) will be 7323.99.9080, Harmonized Tariff Schedule of the United States (HTSUS), which provides
for “Table, kitchen or other household articles and parts thereof, of iron or steel…Other: Other: Other.
Other.” The rate of duty will be 3.4 percent ad valorem.
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 and 9903.81.90. Products provided by heading 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 7323.99.9080,
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 Vietnam 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. 9903.02.69, in addition to subheading 7323.99.9080, 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 Dana L. Giammanco at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division