CLA-2-94:OT:RR:NC:N5:433
Grace Bentz
Lifetime Products Inc.
Freeport Center Bldg. D-12
Clearfield, UT 84016
RE: The tariff classification of plastic furniture from Vietnam
Dear Ms. Bentz:
In your letter dated September 11, 2025, you requested a tariff classification ruling. In lieu of samples,
illustrative literature, a description, and a manufacturing synopsis is provided for review.
Item 81095, the “Display-Sign” is a floor standing “A-Frame” stand constructed of blow molded high density
polyethylene (HDPE) panels. Affixed at the top of each HDPE panel is a polypropylene and steel spring clip;
four polypropylene side tabs that rotate 90 degrees are positioned along the corners of each panel. The stand
will support signs up to 3/16” in thickness. A nylon anchoring strap is positioned between the two panels and
prevents the sign from collapsing. Collectively, the panels, clips, the rotating side tabs, and the anchoring
strap allow for the installation, removal, and secure positioning of signs and messages. The pair of panels are
hollow, for stability the panels can be partially filled with water and then drained when not in use. Each
panel incorporates a removeable round silicon rubber plug for filling and drainage. In the condition at the
time of U.S. importation, the display sign is unassembled and will include an aluminum logo plate along with
all hardware required for assembly. After assembly, the display sign dimensions will approximate 37.9” in
length, 26.1” in width, and weights 18.2 lbs.
The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitutes the
official interpretation of the Harmonized System at the international level.
The ENs to Chapter 94 of the HTS, for “Furniture,” states: “the term “furniture” means: Any “moveable”
articles (not included under other more specific headings of the Nomenclature), which have the essential
characteristic that they are constructed for placing on the floor or ground, and which are used, mainly with a
utilitarian purpose, to equip private dwellings, hotels, theatres, cinemas, offices, churches, schools, cafes,
restaurants, laboratories, hospitals dentists’ surgeries, etc., or ships, aircraft, railway coaches, motor vehicles,
caravan-trailers or similar means of transport. (It should be noted that, for the purposes of this Chapter,
articles are considered to be “movable” furniture even if they are designed for bolting, etc., to the floor, e.g.,
chairs for use on ships). Similar articles (seats, chairs, etc.,) for use in gardens, squares, promenades, etc., are
also included in this category.”
Heading 9403 item (1) includes furniture for “Private dwellings, hotels, etc., such as : cabinets, linen
chests, bread chests, log chests; chests of drawers, tallboys; pedestals, plant stands; dressingtables;
pedestal tables; wardrobes, linen presses; hall stands, umbrella stands; sideboards, dressers,
cupboards; foodsafes; bedside tables; beds (including wardrobe beds, campbeds, folding beds, cots,
etc.); needlework tables; stools and foot-stools (whether or not rocking) designed to rest the feet, fire
screens; draughtscreens; pedestal ashtrays; music cabinets, music stands or desks; playpens; serving
trolleys (whether or not fitted with a hot plate).”
Heading 9403 item (3) includes furniture for “Schools, such as: schooldesks, lecturers’ desks, easels
(for blackboards, etc.).”
The “Display-Sign” is within the construct of Chapter 94 and heading 9403 items (1) and (3); the stand is
moveable plastic furniture akin to plant stands, hall stands, umbrella stands, music stands, and easels. The
piece of furniture will be used for the storage and display of signs and messages.
The applicable subheading for the subject merchandise if constructed of reinforced or laminated plastics will
be 9403.70.4015, HTSUS, which provides for “Other furniture and parts thereof: Furniture of plastics: Of
reinforced or laminated plastics: Other household.” The general rate of duty will be free.
The applicable subheading for the subject merchandise if not constructed of reinforced or laminated plastics
will be 9403.70.8015, HTSUS, which provides for “Other furniture and parts thereof: Furniture of plastics:
Other: Other household.” The general rate of duty will be free.
Trade Remedy:
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 will be
subject to an additional ad valorem rate of duty of 20% percent. 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 subheadings
9403.70.4015 and 9403.70.8015, 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 Dharmendra Lilia at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division