CLA-2:OT:RR:NC:N2:350
Jeffrey Daye
Perrone Performance Leather & Textiles, LLC
dba Perrone Aerospace
182A Riverside Dr.
Fultonville, NY 12072
RE: The tariff classification of a coated fabric from Japan
Dear Mr. Daye:
In your letter dated October 14, 2025, you requested a tariff classification ruling. A sample of the product
was provided to this office and will be retained for training purposes.
The sample submitted, style “Enduralite EDA-xxxx,” is said to be used as fabric in civil aircraft interior
seating. According to your submission, the subject material consists of two layers. The top layer is a
compact layer of polyurethane (“PU”) coated to a plain woven 100 percent aramid backing fabric. You state
the combined material weighs 295 grams per square meter (“g/m2”) in total, and the weight of the PU
coating is 135 g/m2. The fabric will be imported in rolls measuring 54 inches in width.
You suggest that the “Enduralite EDA-xxxx” material be classified in heading 8807, Harmonized Tariff
Schedule of the United States (“HTSUS”), which provides for parts of aircraft. We disagree.
Classification under the HTSUS is made in accordance with the General Rules of Interpretation (“GRI”).
GRI 1 provides that the classification of goods shall be determined according to the terms of the headings of
the tariff schedule and any relative Section or Chapter Notes. However, when classifying parts it is also
necessary to consider Additional U.S. Rule of Interpretation 1(c), HTSUS, which reads, “In the absence of
special language or context which otherwise requires … a provision for parts of an article covers products
solely or principally used as a part of such articles but a provision for “parts” or “parts and accessories” shall
not prevail over a specific provision for such part or accessory.” The material is a fabric used on aircraft
seats. Fabrics are specifically provided for elsewhere in the tariff. Furthermore, the material does not have the
general outline of the final product, nor is it a component without which the aircraft cannot operate. As a
result, classification in heading 8807, HTSUS is precluded.
The applicable subheading for the “Enduralite EDA-xxxx” fabric will be 5903.90.2500, HTSUS, which
provides for “Textile fabrics impregnated, coated, covered or laminated with plastics, other than those of
heading 5902: Other: Of man-made fibers: Other: Other.” The rate of duty will be 7.5 percent 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 Japan 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. At the time of
entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.73, in
addition to subheading 5903.90.2500, 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 Code of Federal 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, please contact
National Import Specialist Michael Capanna at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division