CLA-2-68:OT:RR:NC:N1:128
Ms. Sally Gifford
Geodis US
5101 South Broad Street
Philadelphia, PA 19112
RE: The tariff classification of a compact mirror from China.
Dear Ms. Gifford:
In your letter dated November 17, 2025, you requested a tariff classification ruling on behalf of your client,
Primark US.
The merchandise under consideration is item 991163714, described as a Compact Mirror. It consists of a
stainless steel key ring fitted with a plastic loop strap, a stainless steel lobster claw-style clasp, and a hinged,
rounded star-shaped plastic compact. The two halves of the compact feature glass mirrors framed in plastic.
From the information you provided, the compact measures 7 centimeters wide by 7 centimeters long at its
widest points, and is 7 millimeters thick when closed. You state that the mirrors are made of rolled glass.
The Compact Mirror is constructed of different materials that are classifiable in different headings. The
classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is
governed by the General Rules of Interpretation (GRIs), taken in order. GRI 1 requires that classification be
determined according to the terms of the headings and any relative section or chapter notes. In the event that
goods cannot be classified solely on the basis of GRI 1, and if the heading and legal notes do not otherwise
require the remaining GRIs will be applied, in the order of their appearance. GRI 3(b) provides, in relevant
part, that composite goods which cannot be classified by reference to GRI 3(a) shall be classified as if they
consisted of the material or component which gives them their essential character. The framed mirror
component provides the essential character of the Compact Mirror.
The applicable subheading for the Compact Mirror, item 991163714, will be 7009.92.1090, HTSUS, which
provides for “Glass mirrors, whether or not framed, including rear-view mirrors: Other: Framed: Not over
929 cm2 in reflecting area: Other.” The general rate of duty will be 7.8 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 7009.92.1090, 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 7009.92.1090, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 7009.92.1090, 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 7009.92.1090, 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 Nicole Sullivan at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division