CLA-2-70:OT:RR:NC:N1:128
Ms. Melissa Lehmann
M.Z. Berger & Company, Inc.
353 Lexington Avenue
New York, NY 10016
RE: The tariff classification of framed tabletop mirrors from China.
Dear Ms. Lehmann:
In your letter dated September 9, 2025, you requested a tariff classification ruling.
The merchandise under consideration is item number GNC-GF-3765, “Skeleton Hands Resin Tabletop
Mirror,” and item number GNC-GF-3766, “Skull and Roses Resin Tabletop Mirror.” Please note that the
tariff classifications of the photo frames, item numbers GNC-GF-3763, GNC-GF-3764, GNC-GF-3769, and
GNC-GF-3770, will be addressed in ruling N353516.
From the information you provided, the Skeleton Hands Resin Tabletop Mirror measures approximately 7.25
inches high by 6.7 inches wide at its widest points. It features an oval mirror made of float glass, which
measures approximately 5 inches (12.7 centimeters) high by 4 inches (10.17 centimeters) wide at its widest
points, providing a reflective surface area of approximately 129.5 centimeters squared. The mirror is
surrounded by a black oval molded resin frame. The frame is topped with a pink molded resin bow, and is
decorated on either side by stylized, molded skeleton hands. The back of the mirror features a hinged
easel-style stand.
The Skull and Roses Resin Tabletop Mirror measures approximately 8.64 inches high by 5.83 inches wide at
its widest points. It features a roughly rectangular mirror made of float glass, which measures approximately
5 inches (12.7 centimeters) high by 3.2 inches (8.13 centimeters) wide at its widest points, providing a
reflective surface area of approximately 103.25 centimeters squared. You state that the mirror is made of
float glass. The mirror is surrounded by a black hourglass-shaped molded resin frame. The top of the frame
features a black, molded stylized skull. Both the top and bottom of the frame are also decorated with red
molded resin roses. The back of the mirror features a hinged easel-style stand.
The applicable subheading for item number GNC-GF-3765, “Skeleton Hands Resin Tabletop Mirror,” and
item number GNC-GF-3766, “Skull and Roses Resin Tabletop Mirror” will be 7009.92.1090, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for “Glass mirrors, whether or not framed,
including rear-view mirrors: Other: Framed: Not over 929 cm2 in reflecting area: Other.” The general rate
of duty will be 7.8 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 7009.92.1090, 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 or exclusion
subheading, in addition to subheading 7009.92.1090, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 7009.92.1090, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e.,
9903.88.03, in addition to subheading 7009.92.1090, HTSUS, listed above.
Your imported goods may be subject to additional antidumping and countervailing duties for float glass from
China. 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).
General information regarding the ITA and AD/CVD can be found at
https://www.trade.gov/us-antidumping-and-countervailing-duties. The ITA’s “Guide on How to File for an
Antidumping/Countervailing Duty Scope Ruling Request” is available at
https://enforcement.trade.gov/scope/Request-Scope-Ruling.pdf.
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 Nicole Sullivan at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division