CLA-2-94:OT:RR:NC:N5:433
Nicole Ramsey
William Sonoma Inc.
6300 Fallwater Trail, Suite 100
The Colony, TX 75056
RE: The tariff classification of a seat from China
Dear Ms. Ramsey:
In your letter dated October 21, 2025, you requested a tariff classification ruling. In lieu of samples, technical
and illustrative literature are provided for review.
Item 7969850, the “Slope Dining Chair” is an integrated upholstered seat foundation and backrest affixed to a
powder coated iron frame. Seating is provided for a single individual. The seat contains no armrests. The seat
foundation deck and the seat backrest deck are constructed of wood and foam materials encased in
upholstered fabric. The seat will be manufactured in a variety of colors using genuine leather and vegan
leather upholstery materials. Plastic foot glides are located at the base of each leg. The overall seat
dimensions are 19” in width, 24.4” in depth, 33.3” in height, and a seat weight capacity of 275 lbs. In the
condition at the time of U.S. importation, the seat will be packaged for retail sale as 2 units per carton and
will contain all hardware required for assembly.
The ruling request seeks classification of the seat in subheading 9401.61.4011 Harmonized Tariff Schedule
of the United States (HTSUS) or in subheading 9401.79.0011 HTSUS.
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, Heading 9401 of the Harmonized Tariff Schedule (HTS), for subheading 9401.61
and 9401.71 “Upholstered Seats,” state: “Upholstered seats are those having a soft layer of, for example,
wadding, tow, animal hair, cellular plastics or rubber, shaped (whether or not fixed) to the seat and covered
with a material such as woven fabric, leather or sheeting of plastics. Also classified as upholstered seats are
seats the upholstering materials of which are not covered or have only a white fabric cover which is itself
intended to be covered (known as upholstered seats “in muslin”), seats which are presented with detachable
seat or back cushions and which could not be used without such cushions, and seats with helical springs (for
upholstery). On the other hand, the presence of horizontally-acting tension springs, designed to attach to the
frame a steel wire lattice, taut woven fabric, etc., is not sufficient to cause the seats to be classified as
upholstered. Similarly, seats covered directly with materials such as woven fabric, leather, sheeting of
plastics, without the interposition of upholstering materials or springs, and seats to which a single woven
fabric backed with a thin layer of cellular plastics has been applied, are not regarded as upholstered seats.”
The “Slope Dining Chair” foam and wooden material components will be upholstered and encased in genuine
or vegan leather. In view of these facts, the subject article falls within the construct of Chapter 94, heading
9401, and subheadings 9401.61 and 9401.71 ENs for upholstered seats. Additionally, after assembly, the
integrated seat foundation and backrest will be permanently affixed to metal frame seat legs, not wood frame
seat legs.
The applicable subheading for the subject merchandise will be 9401.71.0011, HTSUS, which provides for
“Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Other
seats, with metal frames: Upholstered: Other household.” The general rate of duty will be free.
Trade Remedy:
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 10 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 9401.71.0011 HTSUS, listed above.
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 9401.71.0011, 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 China will be
subject to an additional ad valorem rate of duty of 10 percent. 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. 9903.01.25, in addition to subheading
9401.71.0011, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 9401.71.0011, HTSUS, unless specifically excluded, are subject to an additional xx percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.04,
in addition to subheading 9401.71.0011, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively.
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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division