CLA-2-94:OT:RR:NC:N5:433
Kelly Harrison
6304 Westborough Dr.
Raleigh, NC 27612
RE: The tariff classification of a RoadLoft Minivan Camper Conversion Kit from Canada
Dear Ms. Harrison:
In your letter dated January 23, 2026, you requested a tariff classification ruling. In lieu of samples,
illustrative literature and a product description were provided.
The “RoadLoft Camper Conversion Kit” is constructed of poplar plywood and designed to temporarily
transform an SUV into a camper van. The kit consists of a satin finished bedframe that holds a sectional
high-density polyurethane foam mattress for the top of the platform. The subject merchandise contains slide
out storage compartments for the placement of articles and objects. Illustrations provided detail that the
product will overlap the rear seating. The kit weighs approximately 62 lbs. and measures 72" in length, 48" in
width above the seats, 40" in width in the trunk, and has an adjustable height of 9.75 to 15.75".
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 of the Harmonized Tariff Schedule (HTS), for “Furniture,” states: “the term
‘furniture’ means: (A) Any ‘moveable’ articles (not included under other more specific headings of the
Nomenclature), which have the essential characteristic that they are constructed for placing on the floor or
ground, and which are used, mainly with a utilitarian purpose, to equip private dwellings, hotels, theatres,
cinemas, offices, churches, schools, cafes, restaurants, laboratories, hospitals dentists’ surgeries, etc., or
ships, aircraft, railway coaches, motor vehicles, caravan-trailers or similar means of transport. (It should be
noted that, for the purposes of this Chapter, articles are considered to be ‘movable’ furniture even if they are
designed for bolting, etc., to the floor, e.g., chairs for use on ships). Similar articles (seats, chairs, etc.,) for
use in gardens, squares, promenades, etc., are also included in this category.”
Further, the ENs to Chapter 94, heading 9403 of the HTS, provides “This heading covers furniture and parts
thereof, not covered by the previous headings. It includes furniture for general use (e.g., cupboards, show
cases, tables, telephone stands, writing desks, escritoires, book cases, and other shelved furniture (including
single shelves presented with supports for fixing them to the wall), etc.), and also furniture for special uses.”
In view of the facts provided, the “RoadLoft Camper Conversion Kit” is within the construct of the Chapter
94 ENs and Heading 9403 ENs for furniture (See New York Ruling Letter (NYRL) N320079 dated June 23,
2021).
The applicable subheading for the subject merchandise will be subheading 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.
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