CLA-2-94:OT:RR:NC:N5:433
Hae Jun Kwon
Hyundai Motor Company
231, Yangjae-Dong, Seocho-Gu
Seoul 06797
Korea, South
RE: The tariff classification of a seat component from South Korea
Dear Hae Jun Kwon:
In your letter dated October 26, 2025, you requested a tariff classification ruling. In lieu of samples,
technical and illustrative literature, product descriptions, and a manufacturing synopsis are provided for
review.
Item 6985357-RBQ and item 6985360-RBQ, the “Quilted Seat Panels,” are composite cut to shape textile
and plastic seating components. Information provided identifies (1) a visible 01.mm exterior polyurethane
(PU) surface, this layer determines the visual aesthetic appearance of the seating components, (2) beneath the
PU surface is 10 mm of cellular plastic, this layer will offer seating comfort and absorb impact, (3) beneath
the cellular plastic is 1.2~1.3mm of tricot fabric, this layer functions as reinforcing material, (4) beneath the
tricot fabric is 0.2 mm of backing cloth, this is an auxiliary material used during stitching operations to bind
the multiple layers together, and (5) a Velcro patch positioned on the rear of the backing cloth. After U.S.
importation, the quilted seat panels will undergo additional manufacture and assembly operations. After U.S.
manufacture, the quilted seat panels will be combined, assembled, and integrated into a finished good; the
finished good will be a complete and upholstered 3-dimensional seat foundation and backrest that will be
permanently affixed into the metal frames of automobile seats according to Original Equipment Manufacturer
(OEM) specifications. The approximate dimensions for the 6985357-RBQ are 21” in length, 13” in width,
and 12 mm thickness. The approximate dimensions for the 6985360-RBQ are 19.5” in length, 14.5” in width,
and 12 mm thickness.
The binding ruling request seeks classification of item 6985357-RBQ and item 6985360-RBQ in heading
9404, Harmonized Tariff Schedule (HTS), which covers “Mattress supports; articles of bedding and similar
furnishing (for example, mattresses, quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or
stuffed or internally fitted with any material or of cellular rubber or plastics, whether or not covered.” We
disagree. These parts are components of a seat cover and, in their condition at time of importation, cannot be
directly used as seat coverings or cushions; they must be further processed in order to function as either a seat
covering or a cushion. Therefore, it is precluded from heading 9404, HTSUS.
Alternatively, the binding ruling request seeks classification of item 6985357-RBQ and item 6985360-RBQ
in heading 3921 HTS, which provides for “Other plates, sheets, film, foil and strip, of plastics: Cellular: of
polyurethanes; combined with textile materials; products with textile components in which man-made fibers
predominate by weight over any other single textile fiber; over 70 percent by weight of plastics.” We
disagree. The products have been further worked and are outside the purview of head 3921 of the HTS.
The applicable subheading for item 6985357-RBQ and item 6985360-RBQ will be 9401.99.1020,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Seats (other than those of
heading 9402), whether or not convertible into beds, and parts thereof: Parts: Other: Of seats of a kind used
for motor vehicles: Of textile material, cut to shape.” The general rate of duty will be free.
Trade Remedy:
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 South Korea
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. 9903.02.56, in addition to subheading
9401.99.1020, 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 Dharmendra Lilia at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division