CLA-2-94:OT:RR:NC:N5:130
Ms. Jen Diaz
Diaz Trade Law
12700 Biscayne Boulevard, Suite 401
North Miami, FL 33181
RE: The tariff classification of a prefabricated home structure from Canada
Dear Ms. Diaz:
In your letter, dated June 9, 2026, you requested a binding tariff classification ruling on behalf of your client,
Honomobo Corporation. Product information and images were submitted for our review.
The product under consideration is a prefabricated building structure for residential use. The structural
framework of the house unit is constructed predominantly of wood. Wood makes up the framing of the floor,
walls, and roof. The unit incorporates some structural steel, but the overall structure of the building is wood.
The unit is pre-assembled before importation and the sections are installed together and fixed to a foundation
on-site. The unit appears to be fully outfitted with electrical and plumbing and is freestanding when
assembled. You indicate that the unit is imported with kitchen appliances. The unit is fully self-contained
and is not designed to be assembled with additional units.
Note 4 to Chapter 94, Harmonized Tariff Schedule of the United States (HTSUS) defines “prefabricated
buildings”:
For the purposes of heading 9406, the expression "prefabricated buildings" means buildings which are
finished in the factory or put up as elements, entered together, to be assembled on site, such as
housing or worksite accommodation, offices, schools, shops, sheds, garages or similar buildings.
The Explanatory Notes to heading 9406 provide that prefabricated buildings consist of:
· complete buildings, fully assembled, ready for use;
· complete buildings, unassembled;
· incomplete buildings, whether or not assembled, having the essential character of
prefabricated buildings.
In the case of buildings presented unassembled, the necessary elements may be presented partially
assembled (for example, walls, trusses) or cut to size (beams, joists, in particular) or, in some cases, in
indeterminate or random lengths for cutting on the site (sills, insulation, etc.).
The instant units are housing units that are complete buildings, partly assembled and substantially finished in
the factory. They are to be entered as self-contained structures to be installed on a foundation and connected
to electric and plumbing services. The units meet the definition of prefabricated buildings.
You suggest that the units are classifiable under 9406.10.0000, HTSUS, which provides for prefabricated
buildings of wood. We agree. The structure of the housing unit consists substantially of wood.
The applicable subheading for the prefabricated residential building structures will be 9406.10.0000, HTSUS,
which provides for Prefabricated buildings: Of wood. The general rate of duty will be 2.6 percent ad
valorem.
Please note that the appliances are classified separately, with the exception of the cooktop. The Explanatory
Notes to heading 9406 explain that
The buildings of this heading may or may not be equipped. However, only builtin equipment
normally supplied is to be classified with the buildings. This includes electrical fittings (wiring,
sockets, switches, circuitbreakers, bells, etc.), heating and air conditioning equipment (boilers,
radiators, air conditioners, etc.), sanitary equipment (baths, showers, water heaters, etc.), kitchen
equipment (sinks, hoods, cookers, etc.) and items of furniture which are built in or designed to be
built in (cupboards, etc.).
The appliances are separate units not built-in and not normally supplied. They are, therefore, to be classified
separately.
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 Laurel Duvall at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division