CLA-2-94:OT:RR:NC:N5:33
Haibo Zheng
Big Tree Sales Inc.
11715 Clark Street
Arcadia, CA 91006
RE: The tariff classification of seats from China
Dear Haibo Zheng:
In your letter dated March 17, 2026, you requested a tariff classification ruling. In lieu of samples, technical
and illustrative literature were provided for review.
Item 1, SKU 2730857, the “Two Seat Beach Chair with Umbrella,” is a pair of collapsible steel metal frame
seats, a collapsible storage compartment, and an umbrella. The seat foundations, backrests, armrests,
cupholders, and the storage compartment are constructed of polyester textile fabric and polyester textile
seating and backing materials. The umbrella component is constructed of polyester textile. The pair of seats
and the storage compartment components are adapted one-to-the-other and form a unitary whole; the seats
and the storage compartment do not disengage and do not detach from one another. The seats, the storage
compartment, and the umbrella are designed to be placed on the floor or ground and used by the occupants
for protection from the outdoor elements while sitting. The seats, the storage compartment, and the umbrella
will collapse, and are designed for storage and transport in a carrying bag. The overall product dimensions
are approximately 63" in length, 22" in width, and 70" in height. The product will be packaged in one box
and will be offered for retail sale as a single unit.
Item 2, SKU 2735107, the “Big Easy Hard Armchair,” is a collapsible aluminum metal frame seat. The seat
foundation and the backrest are constructed of textile seating and backing materials. The seat will collapse
and is designed for storage and transport in a carrying bag. The overall product dimensions are
approximately 25" in length, 32" in width, and 39" in height.
Item 1 and item 2 will provide portable seating for outdoor recreation such as camping, hunting, fishing,
beach, concerts, and sporting events.
The ruling request seeks classification of item 1 in subheading 9401.79.0011, Harmonized Tariff Schedule of
the United States, (HTSUS) and item 2 in subheading 9401.79.0035 HTSUS. We disagree.
The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitutes the
official interpretation of the Harmonized System at the international level.
EN IX to General Rule of Interpretation (GRI) 3(b) provides: “for the purposes of this Rule, composite
goods made up of different components shall be taken to mean not only those in which the components are
attached to each other to form a practically inseparable whole but also those with separable components,
provided these components are adapted one to the other and are mutually complementary and that together
they form a whole which would not normally be offered for sale in separate parts.”
Item 1 is a composite good comprised of different materials (steel, plastic, textile) and different components
(pair of seats, storage compartment, umbrella). The metal seat frames, plastic footrests, and the textile
seating raw material components are adapted one to the other, are mutually complementary, and together they
form a unitary whole. Further, the seats, storage compartment, and the umbrella are adapted one to the other,
are mutually complementary, and together they form a unitary whole.
Item 2 is a composite good comprised of different materials (aluminum, plastic, textile). The metal seat
frames, plastic footrests, and the textile seating raw material components are adapted one to the other, are
mutually complementary, and together they form a unitary whole.
For items 1 and 2, the collapsible metal frame components and the textile seating material components
provide for structural integrity, secure mounting and fitting, and positioning of the complete seating units.
The metal frames and the textile fabric are the indispensable attribute that strongly marks or serves to
distinguish the structure, core or condition of each article. The essential character of item 1 and item 2, as a
whole, is imparted by the metal frame textile seating components.
The applicable subheading for item 1 and item 2 will be 9401.79.0015, HTSUS, which provides for “Seats
(other than those of heading 9402), whether or not convertible into beds, and parts thereof: Other seats, with
metal frames: Other: Other: Outdoor: With textile covered cushions or textile seating or backing material:
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 the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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