CLA-2-94:OT:RR:NC:N5:433
Deana Smith
The William Carter Company
3438 Peachtree Rd., Suite 1800
Atlanta, GA 30326
RE: The tariff classification of a seat from Vietnam
Dear Ms. Smith:
In your letter dated November 12, 2025, you requested a tariff classification ruling. In lieu of samples,
illustrative literature, and a description is provided for review.
Item 9T449510, the “Loop Highchair,” is an unupholstered molded plastic seat foundation, backrest, and
footrest affixed to a four-post powder coated steel frame. The molded plastic seat component is removeable
and is secured to the four-post frame by latching to a square metal hub loop that is located at the top of the
seat’s metal frame. The highchair folds with or without the seat in the hub loop. Seating will be provided for
a single individual. The highchair has three seating positions (tilting, recline 1, recline 2) and will include a
five-point tether safety harness. The molded plastic seat component will support and posture a child in an
upright position until they can sit unassisted. Incidental non-seat components include a removeable plastic
feeding tray and a plastic step stool. Located at the base of the highchair is a step and standing platform. The
overall dimensions approximate 23.2” in width, 25.1” in depth, 45.7” in height, and the seat weight capacity
is 175lbs.
Optional configurations and components (one-piece molded foam seat liner, fully sewn fabric seat made of
two layers with a stuffing) are identified, but are not explicitly included with the instant seat. Rulings are
issued with regard to specific facts, the optional configurations and features described are not under
consideration in this ruling letter.
The binding ruling request seeks classification of the subject article in subheading 9401.79.0001 of the
Harmonized Tariff Schedule of the United States (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 HTS, provides: “lounge chairs, arm-chairs, folding chairs, desk
chairs, infants’ high chairs and children’s seats designed to be hung on the back of other seats (including
vehicle seats), grandfather chairs, benches, couches (including those with electrical heating, settees, sofas,
ottomans and the like, stools (such as piano stools, draughts men’s stools, typists’ stools, and dual purpose
stool-steps), seats which incorporate a sound system and are suitable for use with video game consoles and
machines, television or satellite receivers, as well as with DVD, music CD, MP3 or video cassette players” as
exemplars for seats classified in heading 9401, HTSUS.
Further, “Seats of this heading may incorporate complementary non-seat components, for example, toy
components, a vibration function, music or sound players, as well as lighting features.”
The subject article is within the construct of the Chapter 94, Heading 9401 ENs for seats. A defining
characteristic of a highchair is the height to which it can raise a child; specifically, to raise a child to a height
that adults find useful, typically the height of a table or kitchen counter, for eating or activities with adults.
The seat will provide for dining and feeding of infants aged 3 months to 3 years; when the child is able to sit
upright, the seat will boost them for dining and feeding. The “Loop Highchair” can raise a child
approximately 45.7” off of the ground. In view of the facts provided, the seat is not more specifically
provided for elsewhere in the tariff schedule.
The applicable subheading for the subject article will be 9401.79.0001, 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: Other: Highchairs and booster seats.” 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
9401.79.0001, 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