CLA-2-87:OT:RR:NC:N2:201
Adam Odgaard
Isabella USA LLC
11541 Langton Walk
Zionsville, IN 46077
RE: The tariff classification of a mobile housing trailer from Denmark
Dear Mr. Odgaard:
In your letter dated September 30, 2025, you requested a tariff classification ruling.
The item under consideration has been identified as the Camp-let Earth folding trailer tent. You state that
each unit will be shipped as a fully assembled mobile trailer tent.
The Camp-let Earth is a compact folding camping trailer designed to provide a temporary recreational
dwelling. It consists of a lightweight trailer chassis fitted with a fiberglass/polyester body and an integrated
folding tent structure. When folded for transport, the unit resembles a small luggage trailer; when opened, it
unfolds into an 18 m² (194 sq ft) living quarter.
You state the Camp-let Earth possesses the following key features:
Dimensions and capacity: The trailer in its transport configuration measures approximately 323 cm (L)
× 160 cm (W) × 95 cm (H)
Fully opened trailer measures 569 cm (L) × 400 cm (W) with two sleeping cabins measuring about 215
cm × 160 cm
Living area is about 2.75 m long and provides full standing height
Standard arrangement accommodates four persons in two double beds
Optional annexes increase capacity to six or more
Trailer provides 18 m² of floor area (including the veranda) and can be expanded with optional
modules for an additional 10 m² of living space
Weight and loading: Each unit has a net (unladen) weight of either 270 or 295kg. depending on
whether trailer is equipped with brakes
Aerodynamic profile allows it to be towed by small vehicles and electric cars, and no U.S. trailer
endorsement is required
Materials and construction: The trailer body and floor are made of fiberglass/polyester
Tent portion is made of acrylic canvas that is breathable, water-repellent, mold resistant and treated to
resist dirt and sun heat
Supporting frame and chassis are constructed of galvanized steel tubing for strength and durability.
Based on its design and intended use you state that you believe the product should fall under subheading
8716.39.00, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “other trailers
and semitrailers, for housing or camping.” This office disagrees. The proposed subheading does not provide
for trailers for housing or camping.
The applicable subheading for the Camp-let Earth will be 8716.10.0030, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for “Trailers and semi-trailers; other vehicles, not mechanically
propelled;…: Trailers and semi-trailers for housing or camping: Less than 10.6 m in length.” The general rate
of duty will be Free.
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, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as
products of Chapter 73 provided by 9903.81.89 and 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. 9903.81.91, in addition to subheading 8716.10.0030, 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 the European
Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15
percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General
duty rate. For products covered by heading 9903.81.91 this additional duty applies to the non-steel content of
the merchandise. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.02.20, in addition to subheading 8716.10.0030, 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 Matthew Sullivan at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division