CLA-2-94:RR:NC:N5:433
Kevin Zhuang
Bestqi Innovation (Hong Kong) Technology Co., Ltd.
Rm 4, Unit G, 4/F, Block 1, Koon Wah Mirror Factory (6th) Industrial Building
7-9 Ho Tin Street, Tuen Mun, New Territories
Hong Kong 999077
China
RE: The tariff classification of bedroom furniture from China
Dear Mr. Zhuang:
In your letter dated March 26, 2026, you requested a tariff classification ruling. In lieu of samples, technical
and illustrative literature, and a product description were provided for review.
Item BEFZ0029, the “Queen Loft Bed with Integrated Stairs and Storage” is a floor standing bed frame
surround (chassis) constructed of powder coated steel, medium density fiberboard (MDF) panels, and
particleboard panels. The steel metal frame chassis is not mechanically adjustable and is not foldable. The
steel metal frame chassis provides structure, support, and stability to the bed frame, bed foundation, banister
rail, stairs, and storage cavities. The MDF panels and the particleboard panels create the loft bed stairs and
the storage space. Information provided states the article is a “[C]omplete sleeping furniture unit with
elevated platform, built-in stairs, and under-bed storage. Combines steel structure with wood-based panels for
residential bedroom space optimization.” The article’s overall dimensions approximate 109” in length, 73”
in width, 81” in height, and a load capacity of 1,000 lbs. The bed frame will be imported unassembled, will
include hardware for assembly, packaged in two boxes, and will be sold together at retail sale as one unit.
The mattress component will be imported and sold separately.
The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitutes the
official interpretation of the Harmonized System at the international level.
The Harmonized Tariff Schedule (HTS), Chapter 94, Legal Note 2, 2(a) and 2(b) provides: “articles (other
than parts) referred to in headings 9401 to 9403 are to be classified in those headings only if they are
designed for placing on the floor or ground. The following are, however, to be classified in the
above-mentioned headings even if they are designed to be hung, to be fixed to the wall or to stand one on the
other:
2(a) Cupboards, bookcases, other shelved furniture (including single shelves presented with supports
for fixing them to the wall) and unit furniture.
2(b) Seats and Beds.”
A review of the facts finds the “Queen Loft Bed with Integrated Stairs and Storage” falls within the construct
of Chapter 94, Legal Note 2, 2(a) and 2(b). The loft bed frame surround is floor standing furniture; once
assembled, a mattress may be placed into the elevated bed frame. Additionally, the storage cavities
incorporated into the bed frame surround creates a storage space akin to a bookcase.
Further, EN VIII to General Rule of Interpretation (GRI) 3(b) provides: “the factor which determines
essential character will vary as between different kinds of goods. It may, for example, be determined by the
nature of the material or component, 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 consisted only of the material or component that imparts
the essential character to the composite good.
The bed frame surround, bed foundation slats, banister rail, and the metal rail stair components are 60% of
the material cost and 70% of the product’s total weight. The MDF and the particleboard panel components
are 40% of the material cost and 30% of the product’s total weight.
In view of the facts provided and considering the functionality, bulk, cost, and weight, the loft bed metal
frame chassis is the indispensable attribute that strongly marks or serves to distinguish the structure, core or
condition of the item. The essential character of the “Queen Loft Bed with Integrated Stairs and Storage,” as
a whole, is imparted by the metal components.
The applicable subheading for the subject merchandise will be 9403.20.0040, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for “Other furniture and parts thereof: Other metal furniture:
Household: Other: Mattress bases with legs, not foldable, having the characteristics of a stationary (not
mechanically adjustable) bed frame, of a width exceeding 91.44 cm, of a length exceeding 184.15 cm and of
a depth exceeding 8.89 cm.” 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