CLA-2-83:OT:RR:NC:N5:121
Jenna Belyea
Venturi Inc
2299 Traversefield Drive
Traverse City, MI 49684
RE: The tariff classification of steel and bamboo bathroom racks from China
Dear Ms. Belyea:
In your letter dated January 21, 2026, you requested a tariff classification ruling on three carbon steel and
bamboo bathroom storage baskets and one steel hook.
The first article under consideration is described as a metal and bamboo suction cup metal soap saver. It is
made of steel wire and includes a bamboo insert in the bottom. The bamboo insert has three diagonal slots for
drainage. The soap holder has a flat steel railing at the top that functions to secure the soap placed on the rack
and two “S” hooks that hang from the bottom wire for additional storage. It includes one suction cup made of
thermoplastic elastomer (TPE) for affixing the soap dish to a shower wall or other vertical surface.
The second article under consideration is described as a metal and bamboo suction shower basket. It is made
of steel wire and includes a bamboo insert in the bottom. The bamboo insert has four diagonal slots for
drainage. The shower basket has a flat steel railing at the top that functions to secure the contents placed on
the rack and two “S” hooks that hang from the bottom wire for additional storage. It includes two TPE
suction cups for affixing the shower basket to a shower wall or other vertical surface.
The third article under consideration is described as a metal and bamboo suction cup corner basket. This
triangular shaped basket is made of steel wire and includes a bamboo insert in the bottom. The bamboo insert
has four diagonal slots for drainage. The corner basket has a flat steel railing at the top that functions to
secure the contents placed on the rack and two “S” hooks that hang from the bottom wire for additional
storage. It includes two TPE suction cups for affixing the corner basket to a shower wall or other vertical
surface.
The fourth article under consideration is described as a metal and bamboo suction cup hook. It is a steel hook
with one TPE suction cup to affix it to the wall. The hook does not include any bamboo.
The metal and bamboo suction cup soap saver, shower basket and corner basket are composed of different
components (steel wire, bamboo, and TPE) and are considered composite goods. The Explanatory Notes to
the Harmonized Tariff Schedule of the United States (HTSUS), GRI 3(b) (VIII), state that the factor which
determines essential character will vary between different kinds of goods. It may for example, be determined
by the nature of the materials or components, its bulk, quantity, weight or value, or by the role of a
constituent material in relation to the use of the goods. When the essential character of a composite good can
be determined, the whole product is classified as if it consists only of the material or component that imparts
the essential character to the composite good. It is the steel wire that forms the structure of each of these wall
mounted racks. Therefore, we find that the steel component imparts the essential character.
The applicable subheading for the wall mounted metal and bamboo suction cup soap saver, shower basket
and corner basket, and the metal suction cup hook will be 8302.50.0000, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for Base metal mountings, fittings and similar articles suitable for
furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like; base
metal hat racks, hat-pegs, brackets and similar fixtures; …: Hat-racks, hat pegs, brackets and similar fixtures,
and parts thereof. The 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 Jennifer Jameson at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division