CLA-2-94:OT:RR:NC:N5:433
Ricardo Del Campo
Matamoros Holdings S. de R.L. de C.V.
Libramiento Torreon - Saltillo S/N
Matamoros 27440
Mexico
RE: The tariff classification of a seat from Mexico.
Dear Mr. Del Campo:
In your letter dated January 13, 2026, you requested a tariff classification ruling. In lieu of samples,
illustrative literature and a product description were provided.
The “Madison Hybrid Sofa,” is an upholstered seat affixed to a wooden frame. The sofa does not incorporate
a removeable mattress, convert into a bed, or include recline mechanisms. Seating is provided for one or
more individuals. Illustrative literature states, the seat has (1) removeable duvet style seat cushions (25%
feather / 75% ball fiber) encased in down proof ticking, (2) multi-layered and contoured polyurethane (PU)
foam, and (3) elastic webbing incorporated into the backrest components that are permanently affixed to the
wooden frame. The wooden frame consists of linear and non-linear cut to shape oriented strand board (OSB)
and poplar wood panels along with concave and convex OSB and poplar wood panels that provide the sofa
with its shape and structure. The OSB and the poplar wood are present throughout the seat’s armrests,
backrests, forward frame, and the rear frame. The seat foundation is constructed in part of steel rail
surrounds and steel springs that are mounted to the OSB and poplar wood frame. A pair of parallel steel
metal rails located at the front and rear base of the sofa are mounted to the OSB and poplar wood frame.
Four chrome plated metal legs are located at the base corners of the sofa and are mounted to the OSB and
poplar wood frame. The seat dimensions are 40" in depth, 33" in height, and 83" in length.
The ruling request seeks classification of the subject merchandise in subheading 9401.71.0011, Harmonized
Tariff Schedule of the United States (HTSUS), in accordance with General Rule of Interpretation (GRI) 3(b)
and alternatively, GRI 3(c). We disagree.
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 Harmonized Tariff Schedule (HTS), for subheading 9401.61
and 9401.71 “Upholstered Seats,” states: “Upholstered seats are those having a soft layer of, for example,
wadding, tow, animal hair, cellular plastics or rubber, shaped (whether or not fixed) to the seat and covered
with a material such as woven fabric, leather or sheeting of plastics. Also classified as upholstered seats are
seats the upholstering materials of which are not covered or have only a white fabric cover which is itself
intended to be covered (known as upholstered seats “in muslin”), seats which are presented with detachable
seat or back cushions and which could not be used without such cushions, and seats with helical springs (for
upholstery). On the other hand, the presence of horizontally-acting tension springs, designed to attach to the
frame a steel wire lattice, taut woven fabric, etc., is not sufficient to cause the seats to be classified as
upholstered. Similarly, seats covered directly with materials such as woven fabric, leather, sheeting of
plastics, without the interposition of upholstering materials or springs, and seats to which a single woven
fabric backed with a thin layer of cellular plastics has been applied, are not regarded as upholstered seats.”
Subheadings 9401.61 and 9401.69 (seats with wooden frames), and 9401.71 and 9401.79 (seats with metal
frames) of the HTSUS, contains language in their greater subheadings based on a seat’s frame. There is no
need to take into account the composite nature of the goods under GRI 3(b) or 3(c). (See New York Ruling
Letter N289071 dated August 25, 2017, and Headquarters Ruling Letter HQ H290176 dated May 30, 2019).
Further, EN III to GRI 1 states, “the second part of this Rule provides that classification shall be determined:
(a) according to the terms of the headings and any relative Section or Chapter Notes, and
(b) where appropriate, provided the headings or Notes do not otherwise require, according to the
provisions of Rule 2, 3, 4, and 5.”
The “Madison Hybrid Sofa” is a wood frame seat encased in upholstered fabric; the terms of the heading are
satisfied.
The applicable subheading for the subject merchandise will be 9401.61.6011, HTSUS, which provides for
“Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Other
seats, with wooden frames: Upholstered: Other: Other household.” The general rate of duty will be free.
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 Dharmendra Lilia at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division