CLA-2-44:OT:RR:NC:N5:130
Ms. Jennifer Charney
Princess House
20 Cabot Blvd.
Suite 105
Mansfield, MA 02048
RE: The tariff classification of a wooden cutting board from China
Dear Ms. Charney:
In your letter, dated August 3, 2026, you requested a binding tariff classification ruling on a wooden cutting
board with storage system. Product information and photos were submitted for our review.
The product under consideration is Item 10762 PH Prep Cutting Board System. The item is a two-sided
acacia wood (Acacia spp., a tropical wood) cutting board with a removable steel strainer, two removable steel
storage bins with lids, and a removable steel support rack.
The cutting board is composed of multiple separable items that are classifiable in different headings. The
Explanatory Notes to the Harmonized System (ENs) indicate that a composite good may be “separable
components, provided these components are adapted one to the other and are mutually complementary and
that together they form a whole which would not normally be offered for sale in separate parts.” This
describes the instant cutting board system. It is therefore a composite good classifiable in accordance with
GRI 3(b). The ENs, General Rules of Interpretation (GRI) 3(b) (VIII), state that “the factor which
determines essential character will vary between different kinds of goods. It may for example, be determined
by the nature of the materials or components, 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 wooden cutting board is the main component of the cutting board system, not only by weight and value,
but by function. It is the component that imparts the main use and the strainer, storage bins, and support rack
are secondary to the use of the cutting board. Therefore, the wooden cutting board imparts the essential
character of the cutting board system.
In your letter, you suggest the cutting board is classifiable under subheading 4419.90.9100, Harmonized
Tariff Schedule of the United States (HTSUS) which provides for kitchenware of wood other than bamboo or
tropical wood. We disagree. The cutting board is made of acacia wood, which is identified as a tropical
wood within the Appellation of Certain Tropical Woods in the ENs to Chapter 44.
The applicable subheading for Item 10762 PH Prep Cutting Board System will be 4419.20.9000, HTSUS,
which provides for Tableware and kitchenware, of wood: Of tropical wood: Other. The general rate of duty
will be 3.2 percent ad valorem.
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