CLA-2-94:OT:RR:NC:N2:349
Ms. Jing Lou
58 Britt Ct.
Alameda, CA 94502
RE: The tariff classification of a quilted mattress topper and memory foam pad from China
Dear Ms. Lou:
In your letter dated March 28, 2026, you requested a tariff classification ruling. In lieu of a sample,
photographs were submitted along with your request.
Style RNGMT, described as a “Quilted Mattress Topper,” consists of two separate components, a memory
foam pad and a quilted mattress topper, designed to be placed on top of an existing mattress. The memory
foam pad is a 3-inch-thick rectangular shaped piece with square corners of polyurethane foam; it has not been
further worked. It provides a supportive foundation for sleepers who prefer a firmer sleeping surface. The
quilted mattress topper has an outer shell of 100 percent polyester knit fabric that is stuffed with loose
polyester fibers and/or shredded polyurethane foam. The layers are quilted together to form a 2-inch thick
comfort layer. The mattress topper includes a 100 percent polyester elasticized knit skirt that wraps around
the mattress, securely anchoring both the quilted comfort surface and the supportive memory foam pad in
place. You state that the memory foam pad and quilted mattress topper are always imported and sold
together but are packaged separately. You also state that these layers can be used either separately or
combined for the full 5-inch profile. The quilted mattress topper and pad are available in the following sizes:
Twin, 39 x 75 inches; Twin XL, 39 x 80 inches; Full, 54 x 75 inches; Queen, 60 x 80 inches; King, 78 x 80
inches; and California King, 72 x 84 inches.
The Explanatory Notes, which constitute the official interpretation of the Harmonized Tariff Schedule of the
United States, (HTSUS), at the international level, state in Note (X) to Rule 3 (b) that the term "goods put up
in sets for retail sale" means goods which:
(a) consist of at least two different articles which are prima facie, classifiable in different headings;
(b) consist of products or articles put up together to meet a particular need or carry out a specific
activity;
(c) are put up in a manner suitable for sale directly to users with repacking
The subject items, the quilted mattress topper and memory foam pad, are imported in the same shipment but
are packaged separately. Under General Rule of Interpretation (GRI) 3(b), articles must be "put up in a
manner suitable for sale directly to users without repacking" to be considered a "set" for tariff purposes.
Because the mattress topper and the memory foam base are physically separated into different packages, they
fail to meet the "put up together" requirement under criterion (b). Consequently, the merchandise does not
constitute a "set" for classification purposes of GRI 3(b); therefore, each item must be classified, separately,
under its respective HTSUS heading.
The applicable subheading for the memory foam pad component will be 3921.13.5000, HTSUS, which
provides for “Other plates, sheets, film, foil and strip, of plastics: Cellular: Of polyurethanes: Other.” The
general rate of duty is 4.2 percent ad valorem.
The applicable subheading for the quilted mattress topper component will be 9404.90.9622, HTSUS, which
provides for “Mattress supports; articles of bedding and similar furnishing (for example, mattresses, quilts,
eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed or internally fitted with any material
or of cellular rubber or plastics, whether or not covered: Other: Other: Other: With outer shell of
man-made fibers.” The general rate of duty will be 7.3 percent ad valorem.
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 Kim Wachtel at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division