CLA-2-94:OT:RR:NC:N5:433
Rémy Beaumont
Pantoufle Mobilier
139 Doris-Lussier
St-Augustin-de-Desmaures G3A 2T8
Canada
RE: The tariff classification, United States-Mexico-Canada Trade Agreement (USMCA), and country of
origin of wooden furniture.
Dear Rémy Beaumont:
In your letter dated January 20, 2026, you requested a tariff classification, USMCA, and country of origin
ruling. In lieu of samples, technical and illustrative literature, a product description, and a manufacturing
synopsis were provided for review.
The “Jean-Marie Mid-Century Record Player Stand” is an unassembled wooden storage cabinet. The cabinet
incorporates no electrical components, mechanical components, or integrated speakers. The cabinet is
constructed of solid hardwood (black walnut) and incorporates a tambour sliding door panel (white oak slats)
with textile backing. The cabinet is affixed to detachable solid hardwood legs. The cabinet will allow for the
placement and storage of objects. The cabinet dimensions will approximate 24" in width, 20" in depth, 30" in
height, and will weigh 45 lbs.
The ruling request outlines an operation wherein black walnut hardwood, textile backing, and glue will be
sourced from the United States, metal threaded inserts and screws will be sourced from Germany, and
magnets will be sourced from China. The material components will be shipped and exported to Canada. In
Canada, white oak hardwood will be locally sourced. The manufacturing process undertaken in Canada
involves (1) the black walnut and the white oak hardwood are prepared, joined, and planed using measuring
tools, table saws and miter saws, (2) the black walnut and white oak hardwood are cut to shape using clamps,
jigs, saws, drills, orbital sanders, and routers to fabricate the cabinet case, shelf, back panel, and the legs (3)
wooden door grooves are cut, drilled, and machined in preparation for joining of the cabinet legs with the
cabinet frame, (4) the cabinet door is fabricated using wooden slats and textile backing materials, (5) the
cabinet body and door are assembled using glue, (6) magnets are assembled onto the sliding door, (7) the
cabinet legs undergo sanding and surface preparation using jigs, and (8) the final unassembled cabinet is
coated with an Osmo finish and cured. In Canada, the unassembled wooden cabinet will be inspected,
packaged, and then exported to the United States. Photographs of these processes were provided.
The applicable subheading for the subject merchandise will be 9403.60.8093, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for “Other furniture and parts thereof: Other wooden furniture:
Other: Other: Other.” The general rate of duty will be free.
Eligibility for preferential treatment under the USMCA:
The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30,
2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the
USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note ("GN")
11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is
an originating good for purposes of the USMCA. GN 11(b) states:
For the purposes of this note, a good imported into the customs territory of the United States from the
territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential
tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the
tariff schedule as a "good originating in the territory of a USMCA country" only if-
(i) the good is a good wholly obtained or produced entirely in the territory of one or more
USMCA countries;
(ii) the good is a good produced entirely in the territory of one or more USMCA countries,
exclusively from originating materials;
(iii) the good is a good produced entirely in the territory of one or more USMCA countries
using non-originating materials, if the good satisfies all applicable requirements set forth in
this note (including the provisions of subdivision (o));
Since the “Jean-Marie Mid-Century Record Player Stand” contains non-originating materials, it is not
considered a good wholly obtained or produced entirely in a USMCA country under GN 11(b)(i), nor is the
“Jean-Marie Mid-Century Record Player Stand” produced exclusively from originating materials per GN
11(b)(ii). Thus, we must determine whether the piece of furniture qualifies under GN 11(b)(iii). As
previously noted, the “Jean-Marie Mid-Century Record Player Stand” is classified under subheading
9403.60.8093, HTSUS, the applicable rule of origin is GN 11(o), HTSUS, which provides, in relevant part:
Chapter 94
…4.
(A) A change to subheadings 9403.10 through 9403.89 from any other chapter; or
(B) A change to subheadings 9403.10 through 9403.89 from subheading 9403.90, whether or not
there is also a change from any other chapter, provided there is a regional value content of not less
than:
(1) 60 percent where the transaction value method is used; or
(2) 50 percent where the net cost method is used.
Under GN11(o), Rule 4 and criterion “A” to Chapter 94 HTSUS, the non-originating materials (metal
threaded inserts and screws from Germany, magnets from China) undergoes the permissible tariff shift.
Based on the facts provided, the subject merchandise described above qualifies for USMCA preferential tariff
treatment, because it will meet the requirements of HTSUS General Note 11(b)(iii)(o). The subject
merchandise will therefore be entitled to a free rate of duty under the USMCA upon compliance with all
applicable laws, regulations, and agreements.
Country of Origin:
Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every
article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly,
indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to
indicate to the ultimate purchaser in the United States, the English name of the country of origin of the
article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to
know by an inspection of the marking on the imported goods the country of which the goods is the product.
The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by
knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should
influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940).
Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of
manufacture, production, or growth of any article of foreign origin entering the United States. Further work
or material added to an article in another country must effect a substantial transformation in order to render
such other country the “country of origin” within the meaning of the marking laws and regulations.
Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other
USMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in
sections 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect
to goods imported from Canada and Mexico. Section 102.11 provides a required hierarchy for determining
the country of origin of a good for marking purposes, with the exception of textile and apparel goods which
are subject to the provisions of 19 CFR 102.21. See 19 CFR 102.11.
Applied in sequential order, 19 CFR 102.11(a) provides that the country of origin of a good is the country in
which:
(1) The good is wholly obtained or produced;
(2) The good is produced exclusively from domestic materials; or
(3) Each foreign material incorporated in that good undergoes an applicable change in tariff
classification set out in Part 102.20 and satisfies any other applicable requirements of that section, and
all other applicable requirements of these rules are satisfied.
As the subject merchandise is not wholly obtained or produced in a single country, Rule (1) of § 102.11(a)(1)
is inapplicable. As the subject merchandise is not produced exclusively from domestic materials, Rule (2) of
§ 102.11(a)(2) is inapplicable. Accordingly, Rule (3) applies.
Section 102.20 sets forth specific rules by tariff classification. The pertinent tariff shift rule for subheading
9403.60., HTSUS, states:
A change to subheading 9403.10 through 9403.89 from any other subheading outside that group,
except from subheading 9401.10 through 9403.89, and except from subheading 9401.91 through
9401.99 or 9403.91 through 9403.99, when that change is pursuant to General Rule of Interpretation
2(a).
General Rule of Interpretation 2(a) (“GRI 2(a)”) states:
Any reference in a heading to an article shall be taken to include a reference to that article incomplete
or unfinished, provided that, as entered, the incomplete or unfinished article has the essential
character of the complete or finished article. It shall also include a reference to that article complete or
finished (or falling to be classified as complete or finished by virtue of this rule), entered unassembled
or disassembled.
In view of these facts, since the metal threaded inserts and screws from Germany and the magnets of Chinese
origin will only represent components of the finished cabinet and additional raw materials and other furniture
components will be added in Canada, GRI 2(a) does not apply. Further, since the change from 9403.10
through 9403.89 to 9403.60 Harmonized Tariff Schedule (HTS) will occur as a result of the production in
Canada, the “Jean-Marie Mid-Century Record Player Stand” will undergo the required change in tariff
classification. Therefore, the tariff shift requirement of section 102.11(a)(3) is met. The country of origin of
the “Jean-Marie Mid-Century Record Player Stand” for origin and marking purposes is Canada.
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)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division