CLA-2-94:OT:RR:NC:N5:433
Denise Yapp
Ashley Furniture Industries, LLC.
One Ashley Way
Arcadia, WI 54612
RE: The tariff classification of seats from Vietnam
Dear Ms. Yapp:
In your letter dated October 27, 2025, you requested a tariff classification ruling. In lieu of samples,
illustrative literature and product descriptions are provided for review.
Item 3030525, the “Rocker Recliner,” is a polyester fabric upholstered seat affixed to a blow molded high
density polyethylene (HDPE) plastic frame. Seating is provided for a single individual. The seat incorporates
a steel metal recline mechanism that allows the plastic seat backrest to incline and decline. Further, plywood
encased in polyester fabric is affixed to the rear plastic frame, the plastic armrests, and the reclining footrest.
The reclining mechanism is not mounted to a swivel base, and the rocker recliner does not incorporate
massage functionality. The overall seat dimensions approximate 40” in length, 42” in depth, and 42” in
height.
Item 9860688, the “Dual Reclining Sofa,” is a polyester fabric upholstered seat affixed to a blow molded
HDPE plastic frame. The seat has three seat foundations and three seat backrests; seating is provided for one
or more individuals. The seat incorporates a left and right steel metal recline mechanism that allows the
plastic seat backrests to incline and decline. Further, plywood encased in polyester fabric is affixed to the rear
plastic frame, the plastic armrests, and the reclining footrests. The dual reclining sofa does not incorporate
massage functionality. The overall seat dimensions approximate 87” in length, 40” in depth, and 40” in
height.
The ruling request seeks classification of item 3030525 and item 9860688 in subheading 9401.80.4046,
Harmonized Tariff Schedule of the United States, (HTSUS).
The applicable subheading for item 3030525 and item 9860688 will be 9401.80.4046, HTSUS, which
provides for “Seats (other than those of heading 9402), whether or not convertible into beds, and parts
thereof: Other seats: Of rubber or plastics: Other: Other: Other.” 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 Vietnam will be
subject to an additional ad valorem rate of duty of 20% percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.69, in addition to subheading
9401.80.4046, 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