CLA-2-63:OT:RR:NC:N3:351
Ms. Ella Wang
N-Tech Fabric Supply Inc.
18351 Colima Road, Suite 585
Rowland Heights, CA 91748
RE: The tariff classification of a silt fence with wooden stakes from China
Dear Ms. Wang:
In your letter dated June 24, 2026, you requested a tariff classification ruling. In lieu of a sample,
photographs and videos were provided with your request.
The item, described as a “pocket silt fence with stakes,” consisting of geotextile fabric and 17 wooden stakes
is intended to be used at construction sites to prevent sediment or soil runoff during rain. The geotextile
fabric is composed of 100 percent polypropylene (PP) woven dyed black strips. The PP strips measure
approximately 1.59 to 2.31 millimeters in apparent width and meet the width requirement of Section XI,
Legal Note 1(g) of the Harmonized Tariff Schedule of the United States (HTSUS). The geotextile fabric is
hemmed on both side edges and features 17 pocket sleeves evenly spaced along its length. Each pocket
sleeve measures approximately 4 inches in length by 36 inches in height and contains a pine stake secured
with staples. Each stake measures 2 inches in diameter by 4 feet in height, and stated to be heat treated,
debarked, and free from pests. The stakes will be driven vertically into the ground to hold the fence upright.
The completed silt fence measures 3 feet by 10 feet and is packaged in a roll.
The silt fence is a composite good consisting of a made-up textile fabric (heading 6307) and wooden stakes
(heading 4421). General Rule of Interpretation (GRI) 1, Harmonized Tariff Schedule of the United States
(HTSUS), states in part that for legal purposes, classification shall be determined according to the terms of
the headings, any relative section or chapter notes and, unless otherwise required, according to the remaining
GRI’s taken in order. Goods that are, prima facie, classifiable under two or more headings, are classifiable in
accordance with GRI 3. GRI 3(a) states that the heading which provides the most specific description shall
be preferred to headings providing a more general description. However, when two or more headings refer to
part only of the items in a composite good, those headings are to be regarded as equally specific in relation to
the goods, even if one of them gives a more complete or precise description of the good. As such, they are
regarded as equally specific and classification of the composite good is to be determined by GRI 3(b) or GRI
3(c). GRI 3(b) states in part that composite goods, which cannot be classified by reference to GRI 3(a), are to
be classified as if they consisted of the component which gives them their essential character. It is the
opinion of this office that the made-up textile fabric provides the essential character of the silt fence, as the
fabric performs the primary function of the item by standing vertically to physically trap sediment particles
from runoff water. The wooden stakes are secondary or structural elements that merely support the fabric,
and thus do not determine the essential character of the composite good.
The applicable subheading for the silt fence with wooden stakes will be 6307.90.9891, HTSUS, which
provides for “Other made up articles, including dress patterns: Other: Other: Other: Other: Other.” The
general rate of duty will be 7 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 Kristine Dodge at
[email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division