CLA-2-94:OT:RR:NC:N5:433
Denise Yapp
Ashley Furniture Industries, LLC.
One Ashley Way
Arcadia, WI 54629
RE: The tariff classification of a fire pit table from China
Dear Ms. Yapp:
In your letter dated November 7, 2025, you requested a tariff classification ruling. In lieu of samples,
illustrative literature including pictures, and a product description were provided.
Item number P790-773, the “Rectangle Firepit Table,” is an aluminum metal frame outdoor table encased in
polyvinyl chloride (PVC) wicker with a firepit insert. The table measures approximately 58” in length, 30”
in width, and 25” in height. An aluminum metal cover sits flush in the center of the tabletop surface. When
the aluminum metal cover is removed, the firepit insert is visible. The firepit insert is fueled by propane (a
propane tank is not included), contains decorative glass beads, accounts for 22.6% of the tabletop surface,
and measures approximately 26.75” in length and 11” in width. When the firepit insert is ignited, the
remaining tabletop surface area provides a place for food and beverages. The article’s overall material
construction is 46% aluminum, 11% steel, 25% PE-wicker, 15% glass beads, and 3% plastic.
The binding ruling request seeks classification of the subject merchandise in subheading 9403.20.0050 of the
Harmonized Tariff Schedule of the United States (HTSUS). We agree.
The applicable subheading for the subject merchandise will be 9403.20.0050, HTSUS, which provides for
“Other furniture and parts thereof: Other metal furniture: Household: Other: Other.” The 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 9403.20.0050, 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 9403.20.0050, 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.
On March 12, 2025, Presidential proclamation 10895 imposed additional tariffs on certain derivative
aluminum products. Additional duties for derivative aluminum products of 50 percent are reflected in
Chapter 99, headings 9903.85.04, 9903.85.07, and 9903.85.08. Products provided by heading 9903.85.08, as
well as products of Chapter 76 provided by 9903.85.04 and 9903.85.07, will be subject to a duty of 50
percent upon the value of the aluminum content. At the time of entry, you must report the Chapter 99 heading
applicable to your product classification, i.e. 9903.85.08, in addition to subheading 9403.20.0050, HTSUS.
Derivative aluminum articles processed in another country from aluminum articles that were smelted and cast
in the United States, provided for in heading 9903.85.09, 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 9903.01.25
this additional duty applies to the non-steel and the non-aluminum 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 9403.20.0050, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 9403.20.0050, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03,
in addition to subheading 9403.20.0086, 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