CLA-2-96:OT:RR:NC:N4:415
Raj Bedi
Mr. Oxy Home, Inc.
898 North Broadway
Massapequa, NY 11758
RE: The tariff classification and marking of a mop set from Turkey.
Dear Mr. Bedi:
In your letter dated September 12, 2025, you requested a tariff classification and marking ruling.
Samples were submitted and will be returned separately. The original request consisted of five items. The
four types of cleaning wipes will be addressed in New York ruling N353672. This letter will only address
the mop set.
The product under consideration is described as a set that includes a mop with handle and a package of 50
floor wipes. We hold the opinion that this product would be a set for classification purposes, and it is the
mop that would impart the essential character and provide the classification for this article, General Rule 3(b)
notated.
Your correspondence indicates the mop and wipes are sourced from Turkey and the handle of the mop
includes aluminum.
The applicable subheading for the mop set will be 9603.90.8050, Harmonized Tariff Schedule of the United
States (HTSUS), which provides for “[b]rooms, brushes (including brushes constituting parts of machines,
appliances or vehicles), hand-operated mechanical floor sweepers, not motorized, mops and feather dusters;
prepared knots and tufts for broom or brush making; paint pads and rollers; squeegees (other than roller
squeegees): [o]ther: [o]ther: [o]ther.” The column one, general rate of duty is 2.8% ad valorem.
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 Turkey will be
subject to an additional ad valorem rate of duty of 15 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e., 9903.02.64, in addition to subheading
9603.90.8050, HTSUS, listed above.
On March 12, 2025, Presidential proclamation 10895 imposed additional tariffs on certain derivative
aluminum products. Additional duties for derivative aluminum products of 50 percent are reflected in
Chapter 99, headings 9903.85.04 and 9903.85.07. Products provided by heading 9903.85.08 will be subject
to a duty of 50 percent upon the value of the aluminum content. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e., 9903.85.08, in addition to subheading
9603.90.8050, HTSUS. Derivative aluminum articles processed in another country from aluminum articles
that were smelted and cast in the United States, provided for in heading 9903.85.09, are not subject to the
additional ad valorem duties.
The marking statute, section 304, Tariff Act of 1930, as amended (19 USC 1304), provides that, unless
excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a
conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will
permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country
of origin of the article.
As provided in 19 CFR 134.41(b), the country-of-origin marking is considered conspicuous if the ultimate
purchaser in the U.S. can find the marking easily and read it without strain.
Regarding the permanency of a marking, 19 CFR 134.41(a) provides that, as a general rule, marking
requirements are best met by marking worked into the article at the time of manufacture. For example, it is
suggested that the country of origin on metal articles be die sunk, molded in, or etched. However, 19 CFR
134.44 generally provides that any marking that is sufficiently permanent so that it will remain on the article
until it reaches the ultimate purchaser, unless deliberately removed, is acceptable.
As to the marking of the mop set, we look to the Treasury Decision (T.D.) 91-7, published in Volume 25,
Customs Bulletin and Decisions, at 6 (January 16, 1991), which addressed, among other things, the
application of country of origin marking requirements to sets. It was stated therein, at 16:
… in most cases, the mere inclusion of an item in a collection will not substantially transform it into
an article with a new name, character or use and, therefore, each item must be separately marked with
its own country of origin. (Where the marking of the container will reasonably indicate the country of
origin to the ultimate purchaser, the container may be marked instead of the individual articles. See
19 U.S.C. 1304(a)(3)(D) and 19 CFR 134.32(d)). This result is consistent with the purpose of the
marking statute since the ultimate purchaser’s decision as to whether to buy the set might be
influenced by the country of origin of any of the items in the set, whether or not an item gives the set
its essential character.
As you indicate that both the mop and cleaning wipes are sourced from Turkey, the packaging for this set
should be marked to indicate the country of origin is Turkey.
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 CBP Regulations (19 CFR 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, contact
National Import Specialist Kristopher Burton at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division