CLA-2-84:OT:RR:NC:N1:105
Thibault Richard
Wuensche USA
566 W Adams Street
Chicago, IL 60661
RE: The tariff classification of the Garden Drip Watering Kit and the Garden Tower from China
Dear Mr. Richard:
In your letter dated January 29, 2026, you requested a tariff classification ruling. Descriptive literature and a
sample was provided for our review.
The first item under consideration is the Garden Drip Watering Kit, which is designed to keep plants healthy
while saving time and water (up to 70% less). The device is designed for vegetable gardens, flower beds, and
potted plants, while delivering targeted daily irrigation to up to 35 plants at once. The kit is crafted of
durable, ultraviolet (UV) resistant tubing and plastic components. The plastic components include 100ft of
tubing, a tap connection with pressure regulation, two connecting pieces, five reducers, seven sealing plugs,
two shutoff valves, an in-line dripper, pipe holders, 10 meters of half-inch pipe, and 20 meters of 3/16 inch
pipe.
The second item under consideration is a Garden Tower, which is a floor-standing planter designed with an
integrated vertical gardening system to optimize plant growth. This versatile indoor/outdoor unit features a
tiered, stackable construction crafted from durable, UV-resistant polypropylene (PP) plastic, enabling
maximized vertical gardening even in limited spaces. Measuring 42 inches in height and weighing 850
grams, the Garden Tower is lightweight and easily movable. While its plants require manual watering, the
tower incorporates an internal drainage system that significantly enhances maintenance efficiency.
The applicable subheading for the Garden Drip Watering Kit will be 8424.82.0020, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for “Mechanical appliances (whether or not hand
operated) for projecting, dispersing or spraying liquids or powders; fire extinguishers, whether or not
charged; spray guns and similar appliances; steam or sand blasting machines and similar jet projecting
machines; parts thereof: Other appliances: Agricultural or horticultural: Irrigation equipment: Other.” The
general rate of duty will be 2.4 percent ad valorem.
The applicable subheading for the Garden Tower will be 9403.70.4015, HTSUS, which provides for “Other
furniture and parts thereof: Furniture of plastics: Of reinforced or laminated plastics: 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 Jason Christie at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division