CLA-2-94:OT:RR:NC:N2:349
Mr. Vadim Marmer
PillowFlow LLC
16385 Biscayne Blvd.
Aventura, FL 33160
RE: The tariff classification of an ergonomic support cushion from Taiwan
Dear Mr. Marmer:
In your letter dated December 7, 2025, you requested a tariff classification ruling. In lieu of a sample,
photographs were submitted along with your request.
The item, described as a “PillowFlow™ Thigh Support Pillow,” is an injection-molded cushion intended to
provide support and comfort to commercial and other drivers who sit for prolonged periods while operating a
vehicle. The ribbed wedge-shaped cushion is composed of injection molded ethylene-vinyl acetate (EVA)
foam. It features multi-level, height-differentiated “step ribs” and an adjustable strap composed of
polyester/nylon webbing with a hook-and-loop fastener that is attached through a slot in the cushion. To use,
the cushion is placed on the right side of the driver’s seat, directly under the upper thigh of the operator, and
is secured with the hook-and-loop strap over the belt buckle base or seat frame. You state that the item is
engineered to redistribute pressure, minimize sciatic compression, and enhance blood circulation. The
cushion measures 8 x 4 x 4.5 inches and weighs 9 oz. The item will be sold at retail on its online store at
pillowflow.com.
In your letter, you suggest the "PillowFlow™ Thigh Support Pillow,” as an orthopedic appliance under
heading 9021, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. According to Note
6 to Chapter 90, orthopedic appliances are defined as appliances for preventing or correcting bodily
deformities, or supporting or holding body parts following an illness, operation, or injury. The
“PillowFlow™ Thigh Support Pillow,” as described on your website, is a “comfort aid, not a medical
device,” designed to “support your thigh to reduce pressure and fidgeting on long drives, helping your leg
feel more stable and less fatigued.” This function does not align with the criteria of heading
9021. Furthermore, U.S. Customs and Border Protection (CBP) rulings, including Headquarters Ruling
Letters (HQ) 955010 (December 14, 1993) and 087213 (September 18, 1990), have consistently held that
similar products, such as orthopedic back support pillows and posture aids—even those intended to alleviate
backache, strain, eliminate fatigue, or promote good posture—do not qualify for classification under Heading
9021. Consequently, heading 9021 will not apply.
The applicable subheading for a “PillowFlow™ Thigh Support Pillow,” will be 9404.90.2090, 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: Other: Pillows, cushions and similar
furnishings: Other: Other.” The general rate of duty will be 6 percent ad valorem.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division