CLA-2-94:OT:RR:NC:N5:433
Lachlan Donahoe
Sunwedge
13 Moresby Ave.
Palm Beach 4221
Australia
RE: The tariff classification of a seat from China
Dear Lachlan Donahoe:
In your letter dated April 8, 2026, you requested a tariff classification ruling. In lieu of samples, illustrative
literature and a product description were provided.
The “Sunwedge” is a collapsible, foldable, and portable beach seat that is designed for outdoor leisure. The
Sunwedge is constructed of wood, metal, and textiles. The Sunwedge is not upholstered, and seating will be
provided for one or more individuals. The reclining seat’s 24” left seat leg rail and the 24” right seat leg rail
are constructed of clear coated Acacia hardwood timber; each seat leg end is cut 45 degrees. Each seat leg
incorporates a Tasmanian oak dowel lug and a 10 mm braided cotton cord rope that serves as the 90 degree
pivot and anchor points for the seat’s wooden frame when extended. The braided cotton cord rope is
threaded through the wooden legs and limits the opening of each leg to 90 degrees. The seat backrest and the
seat foundation are constructed of a single panel of ultraviolet (UV) resistant polyester textile fabric. The
canvas panel has a slotted top and bottom loop. During assembly, a pair of 39” in length stainless steel poles
will be inserted horizontally between the loops of the canvas panel. The seat will be imported unassembled,
including all hardware (bolts, washers, locking nuts) for assembly, packaged for retail sale in a travel canvas
storage bag with shoulder straps, and will be sold at retail sale as one unit.
The binding ruling request seeks classification of the subject merchandise in subheading 9401.69.6010 of the
Harmonized Tariff Schedule of the United States (HTSUS). We disagree.
The applicable subheading for the subject merchandise will be 9401.69.8090, HTSUS, which provides for
“Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Other
Seats, with wooden frames: Other: Other: 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 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 P. Forkan
Director
National Commodity Specialist Division