CLA-2-94:OT:RR:NC:N2:349
Ms. Lynn Chen
E&E
45875 Northport Loop E
Fremont, CA 94538
RE: The tariff classification of cotton quilt from China
Dear Ms. Chen:
In your letter dated October 27, 2025, you requested a tariff classification ruling for cotton quilts. An
unmarked sample of the quilt was submitted with your request and will be retained by this office for training
purposes.
The subject merchandise is a quilt. The outer shell is made of 100 percent cotton woven fabric. The shell
fabric is bleached and shrunk. The face fabric is printed with an array of colors including light blue, navy
blue, light brown, and light grey. The back fabric is dyed a solid light blue color. The middle layer consists
of 100 percent cotton nonwoven batting fabric. The three layers are stitched together in straight lines across
the entire surface. The quilt is finished with self-fabric binding composed of 100 percent cotton, and all the
edges are straight. The quilt does not contain any embroidery, lace, braid, edging, trimming, piping or
applique work. The submitted unmarked sample measures 93 × 93 inches and is designed for a queen size
bed. You state that quilt will only be offered in Queen size. At time of importation, the quilt will be
individually packaged in a polyethylene (PE) bag for retail sale. The cotton quilt is intended to be used as a
bed covering.
The applicable classification for the cotton quilt will be subheading, 9404.40.1000, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for “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: Quilts, bedspreads, eiderdowns and duvets (comforters): Of cotton, not containing any embroidery,
lace, braid, edging, trimming, piping exceeding 6.35 mm or applique work.” The general rate of duty will be
4.4 percent ad valorem.
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 9404.40.1000, HTSUS, listed above.
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, Hong
Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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 9404.40.1000, HTSUS, listed above.
You have submitted an unmarked sample. Be advised, the marking statute, section 304, Tariff Act of 1930,
as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin (or its container)
imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly and permanently as the
nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in
the U.S. the English name of the country of origin of the article.
As provided in section 134.41(b), Customs Regulations (19 CFR 134.41(b)), the country of origin marking is
considered conspicuous if the ultimate purchaser in the U.S. is able to find the marking easily and read it
without strain.
With regard to the permanency of a marking, section 134.41(a), Customs Regulations (19 CFR 134.41(a)),
provides that as a general rule marking requirements are best met by marking worked into the article at the
time of manufacture. For example, it is suggested that the country of origin on metal articles be die sunk,
molded in, or etched. However, section 134.44, Customs Regulations (19 CFR 134.44), generally provides
that any marking that is sufficiently permanent so that it will remain on the article until it reaches the ultimate
purchaser unless deliberately removed is acceptable.
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 Kim Wachtel at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division