HS Code Classification Sets Application Rule 2b 3a 3b 3c : Customs Tax Consultant Kenya

RE: The tariff classification of a plastic decoration and a plastic planter from China
In your letter dated September 7, 2022, you requested a tariff classification ruling. Photographs of the items were submitted along with your request.

The first item under consideration is described as a polyresin acorn decoration. The acorn nut is green, and the cap is brown in color. It is molded from one piece, measures approximately 4 inches long by 4 inches wide by 6 inches high and weighs .28 pounds. Your submission indicates two versions, one made from 100% polyresin plastic, the other 80% polyresin plastic, and 20% natural limestone powder.

The second item under consideration is described as a polyresin skull planter. The skeleton skull planter is white in color. It is molded from one piece, measures approximately 7.75 inches long by 6.25 inches wide by 3.87 inches deep and weighs .89 pounds. Your submission indicates two versions, one made from 100% polyresin plastic, the other 80% polyresin plastic, and 20% natural limestone powder.

Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is in accordance with the General Rules of Interpretation (GRIs), taken in order. GRI 1 provides that classification shall be determined according to the terms of the headings and any relative section or chapter notes. Since no one heading in the tariff schedules covers all the components of the acorn decoration and the skull planter in combination, GRI 1 cannot be used as the basis for classification. GRI 3(b) provides that mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale shall be classified as if they consisted of the material or component which gives them their essential character, which may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the article. The acorn decoration and the skull planter containing 80% polyresin and 20% limestone are both composite goods. Both items are polyresin with a small amount of limestone powder. Polyresin is a significant component in both articles and provides the bulk of the composition of the acorn decoration and the skull planter. Therefore, the polyresin in both articles provides the essential character within the meaning of GRI 3(b).

As the acorn is an ornamental article primarily made from plastic, the applicable subheading will be 3926.40.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [s]tatuettes and other ornamental articles: [o]ther.” The general rate of duty is 5.3 percent ad valorem.

As the skull planter is a household utilitarian article primarily made from plastic, the applicable subheading will be 3924.90.5650, HTSUS, which provides for “Tableware, kitchenware, other household articles and hygienic or toilet articles, of plastics: Other: Other. Other.” The general rate of duty will be 3.4 percent ad valorem.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 3924.90.5650, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 3924.90.5650, HTSUS, listed above. The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.

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 on the World Wide Web at https://hts.usitc.gov/current.

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Dana L. Giammanco at dana.l.giammanco@cbp.dhs.gov.

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division

RE: The tariff classification of the “Class of 2022 Car Decorating Kit” from China.

In your letter dated September 6, 2022, you requested a tariff classification ruling.

You submitted a sample identified as the “Class of 2022 Car Decorating Kit,” item number 244366, which consists of a printed banner featuring the phrase “Congrats Grad Class of 2022” along with images of confetti and graduation caps, two fringed garlands and twenty-four printed latex balloons to decorate a car temporarily for a low-speed graduation parade. General Rule of Interpretation 3(b) is applicable when goods are, prima facie, classifiable under two or more headings, and have been put up in sets for retail sale. GRI 3(b) states that the goods “shall be classified as if they consisted of the material or component which gives them their essential character.” The flimsy single use printed banner imparts the essential character of the set. The lightweight banner is made of 0.05mm polyethylene and measures approximately 20″ by 60,” and is affixed to the vehicle by only two tiny suction cups. Reuse of this flimsy, lightweight article is both unlikely due to the printed year and impractical due to its lack of durability. It is marketed and designed for temporary display and to be thrown away after the graduation parade.

The applicable subheading for the “Class of 2022 Car Decorating Kit,” item number 244366, will be 9505.90.400, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Festive, carnival or other entertainment articles, including magic tricks and practical joke articles; parts and accessories thereof: Other: Confetti, paper spirals or streamers, party favors and noisemakers; parts and accessories thereof.” The rate of duty will be Free.

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 on the World Wide Web at https://hts.usitc.gov/current.

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Sandra Carlson at sandra.carlson@cbp.dhs.gov.

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division

RE: The tariff classification of hanging hardware from China

In your letter dated September 2, 2022, you requested a tariff classification ruling.

Item 1, Clear kitchen hooks medium size, and Item 2, Clear kitchen hooks small size, are two styles of hooks. They are made of polystyrene plastic, with an adhesive back, and a plated metal (iron) hook. They will be used to hang lightweight articles in kitchens or bathrooms without making holes in the wall.

The clear kitchen plastic hooks are composed of different components (base metal and plastic) and are considered composite goods. The Explanatory Notes to the Harmonized Tariff Schedule of the United States (HTSUS), 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 consists only of the material or component that imparts the essential character to the composite good. In the case of the subject hooks, we find that the plated metal (iron) hook, which is used to hang various lightweight articles, provides the essential character. As such, the clear kitchen plastic hooks are classified by application of GRI 3(b), according to the metal component.

Item 3, Mop and Broom Gripper, is composed of polyvinyl chloride (PVC) and acrylonitrile-butadiene-styrene (ABS) plastic with an adhesive back. It will be mounted to hold a mop or broom, without making holes in the wall.

Item 4, Picture Hanging Hook, is composed of PVC and polystyrene plastic with an adhesive back. The hooks will be used to hang pictures or other wall hangings without making holes in the wall.

Item 5, Cable clips and holder, is composed of PVC and polystyrene plastic with adhesive backs. The clips and holders will be used to hang and organize cables or light strings without making holes in the wall.

You propose classification of Item 3, Mop & Broom Gripper, Item 4, Picture Hanging Hook, and Item 5, Cable clips and holder in subheading 3924.90.5650. We disagree.

The Explanatory Notes for heading 39.24 (D) covers the following articles of plastics: (D) Hygienic and toilet articles (whether for domestic or non-domestic use) such as toilet sets (ewers, bowls, etc.), sanitary pails, bed pans, urinals, chamber-pots, spittoons, douche cans, eye baths; teats for baby bottles (nursing nipples) and finger-stalls; soap dishes, towel rails, tooth-brush holders, toilet paper holders, towel hooks and similar articles for bathrooms, toilets, or kitchens, not intended for permanent installation in or on walls. However, such articles intended for permanent installation in or on walls or other parts of buildings (e.g., by screws, nails, bolts, or adhesives) are excluded (heading 39.25).

Therefore, classification of these three items in heading 3924, HTSUS, is precluded.

The applicable subheading for Item 1, clear kitchen plastic hooks medium size, and Item 2, clear kitchen plastic hooks small size will be 8302.50.0000, HTSUS, which provides for hat-racks, hat pegs, brackets and similar fixtures, and parts thereof, of base metal. The general rate of duty will be free.

The applicable subheading for Item 3, Mop and Broom Gripper, Item 4, Picture Hanging Hook, and Item 5, Cable clips and holder will be 3925.90.0000, HTSUS, which provides for builders’ ware of plastics, not elsewhere specified or included: other. The general rate of duty will be 5.3 percent ad valorem.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 3925.90.0000 and 8302.50.0000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 3925.90.0000 or 8302.50.0000, HTSUS, listed above. The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.

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 on the World Wide Web at https://hts.usitc.gov/current.

This ruling is being issued under the provisions of Part 177 of the Customs 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 classification in 3925, contact National Import Specialist Christina Allen at julie.c.allen@cbp.dhs.gov or for questions regarding classification in 8302, contact National Import Specialist Jennifer Jameson at jennifer.d.jameson@cbp.dhs.gov.

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division

RE: The tariff classification of a seat having massage components from China.
In your letter dated September 08, 2022, on behalf of your client Bodyfriend Inc., you requested a tariff classification ruling. In lieu of samples, illustrative literature and a product description were provided.

The “Hug-Chair 2.0,” is a seat upholstered in synthetic leather and comprised of built-in electro-mechanical components that independently perform massage and heating functions according to user preference. The footrest, armrests, seat foundation, and backrest are affixed to a metal frame. Seating is provided for a single individual. The ergonomically designed structural frame does not possess restrictive features and does not partially or completely encapsulate a user. Further, the upholstered seat does not enfold or restrain a user’s posterior upper body, arms, legs and feet.

The recline angle of the seat is 130. The leg rest is retractable, as the seat reclines the leg rest extends away from the seat foundation. As the seat inclines, the leg rest returns to the seat foundation. A control panel located on the right armrest allows the user to set desired seat positions and engage or disengage the 4 automatic massage settings or the 5 manual massage settings. Located on the left and right side of the headrest are Bluetooth speakers. The seat dimensions are 35.4″ in length, 25.2″ in width, 20″ in depth, 40.5″ in height, and weighs 99 lbs. The seat operates on regular household voltage.

You propose classification under subheading 9019.10, Harmonized Tariff Schedule of the United States (HTSUS), which provides in part for massage apparatus. We disagree. The chair does not enfold the upper body and does not have restrictive features that would make it uncomfortable or restrict its use as seating. We find that the massage features are complementary non-seat components.

The Harmonized Commodity Description and Coding System Explanatory Notes (“ENs”) constitute the official interpretation of the Harmonized System at the international level.

For the purposes of Chapter 94, HTSUS, the term “furniture” means: Any “moveable” articles (not included under other more specific headings of the Nomenclature), which have the essential characteristic that they are constructed for placing on the floor or ground, and which are used, mainly with a utilitarian purpose, to equip private dwellings, hotels, theatres, cinemas, offices, churches, schools, cafes, restaurants, laboratories, hospitals dentists’ surgeries, etc., or ships, aircraft, railway coaches, motor vehicles, caravan-trailers or similar means of transport. (It should be noted that, for the purposes of this Chapter, articles are considered to be “movable” furniture even if they are designed for bolting, etc., to the floor, e.g., chairs for use on ships). Similar articles (seats, chairs, etc.,) for use in gardens, squares, promenades, etc., are also included in this category.

The ENs to Chapter 94, heading 9401 include: lounge chairs, arm-chairs, folding chairs, desk chairs, infants’ high chairs and children’s seats designed to be hung on the back of other seats (including vehicle seats), grandfather chairs, benches, couches (including those with electrical heating, settees, sofas, ottomans and the like, stools (such as piano stools, draughts men’s stools, typists’ stools, and dual purpose stool-steps), seats which incorporate a sound system and are suitable for use with video game consoles and machines, television or satellite receivers, as well as with DVD, music CD, MP3 or video cassette players under the list of exemplars for seats classified in heading 9401, HTSUS.

Seats of this heading may incorporate complementary non-seat components, for example, toy components, a vibration function, music or sound players, as well as lighting features.

The Hug Chair 2.0 massage seat meets the terms of Chapter 94, HTSUS, as it is a floor standing moveable article used mainly with a utilitarian purpose, that being, to equip private dwellings for rest, relaxation, storage or display and is designed for the personal use, convenience, and comfort of the dweller. The subject article also falls within the construct of heading 9401, HTSUS, in that this heading covers all seats including those that incorporate complementary non-seat components. Further, the term “furniture” embraces articles of utility that are designed for the “use, convenience, and comfort of the dweller,” as distinguished from articles that are “subsidiary adjuncts and appendages designed for the ornamentation of a dwelling or business place, or which are of comparatively minor importance so far as use, comfort, and convenience are concerned.” The built-in massage and heating components of the seat will be used only for brief periods at the discretion of the user, the remainder of the time the seat will perform in a utilitarian capacity, that being furniture. Based on the facts, the subject article is an upholstered seat. Inclusion of the massage and other components do not alter the essential character of the article.

Further, in the alternative, if the article is considered a composite good pursuant to General Rule of Interpretation (GRI) 3(b), its functionality as a chair and as a massage apparatus would be considered equally important. The article would then be classified pursuant to GRI 3(c), and heading 9401 would be the later tariff classification.

The applicable subheading for the subject article will be 9401.71.0011, HTSUS, which provides for “Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Other seats, with metal frames: Upholstered: Other household.” The rate of duty will be free.

Section 301 Trade Remedy: Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9401.71.0011, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.04, in addition to subheading 9401.71.0011, HTSUS, listed above. The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china respectively.

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 on the World Wide Web at https://hts.usitc.gov/current.

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Dharmendra Lilia at dharmendra.lilia@cbp.dhs.gov.

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division

RE: The tariff classification of birdfeeders from China

In your letter dated August 25, 2022, on behalf of your client Classic Brands LLC, you requested a tariff classification ruling. A breakdown of material sheets and photographs were submitted with your request. The importer’s website and samples were also reviewed. Samples have already been sent back to you.

The items concerned are the Sweet Tweet Caf (#50216) and the Squirrel – X1 (#11) bird feeders. Both bird feeders are predominately made from plastic and steel components. The articles are designed for outdoor use.

The first item is referred to as the Sweet Tweet Caf (#50216). It is a cylindrical black wire cage with a red base and red lid. The plastic feed tube is housed inside the feeder. A top steel ring is attached to the top steel lid to hang the item. The feeder measures approximately 7.75 inches long by 7.75 inches wide by 12.25 inches high.

The item contains a polyvinyl chloride (PVC) plastic seed tube. The cage weldment, bottom tray, port with perch, roof, roof locator ring, roof wire form retainer, top cover, finial, hanging ring, and threaded rod are all steel. To fill the feeder with bird seed, the user would unscrew the top ring and lift off the lid and place the seed inside the plastic tube. There are four ports where birds can perch on the feeder. The feeder can hold approximately 1.61 pounds of seed.

The second item is referred to as the Squirrel – X1 (#11). It is a silver cylindrical bird feeder that measures approximately 6.25 inches long by 12 inches wide by 15.5 inches high. The item contains a polystyrene plastic housing. The hinged perch is made of zinc alloy. A port shield, cap, base, moving roof, slider bottom ring, end cap, upper shield is made of steel.

The polystyrene plastic housing is encased in the steel feeder. A steel wire is attached to the top steel lid to hang the item. To fill the feeder, the user would open the top cover and pour the seed into the open top. There are four ports where birds can perch on the feeder. The spring-loaded perch design shuts all ports simultaneously when the weight of a squirrel or larger bird is applied to the perches or lid. The feeder can hold approximately 4.2 pounds of seed.

You propose a classification for both bird feeders in subheading 3924.90.5650, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Tableware, kitchenware, other household articles and hygienic or toilet articles, of plastics: Other: Other. Other.” We disagree.

The steel and plastic bird feeders under consideration are both composite articles. The Sweet Tweet Caf (#50216) is comprised of a PVC plastic seed tube, a steel cage weldment, a steel bottom tray, a steel port with perch, a steel roof, a steel roof locator ring, a steel roof wire form retainer, a steel top cover, a steel finial, a steel hanging ring, and a steel threaded rod. The Squirrel – X1 (#11) is comprised of a polystyrene plastic housing, a zinc alloy hinged perch, a steel port shield, a steel cap, a steel base, a steel moving roof, a steel slider bottom ring, a steel end cap, and a steel upper shield. The steel, zinc alloy, and plastic components are classified in different headings.

Classification of merchandise under the HTSUS is in accordance with the General Rules of Interpretation (GRIs) taken in order. GRI 1 provides that classification shall be determined according to the terms of the headings and any relative section or chapter notes. Since no one heading in the tariff schedule covers the steel, zinc alloy, and plastic components of the bird feeders in combination, GRI 1 cannot be used as a basis for classification. GRI 3(b) provides that mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale shall be classified as if they consisted of the material or component which gives them their essential character. As the steel, zinc alloy, and plastic bird feeders are composite goods, we must apply rule 3(b), which provides that composite goods are to be classified according to the component that gives the goods their essential character.

EN VIII to GRI 3(b) explains that “the factor which determines essential character will vary as between different kinds of goods. It may, for example, be determined by the nature of the material or component, its bulk, quantity, weight, or the use of the goods.” We must determine whether the steel and zinc alloy support, or the plastic components impart the essential character to the article under consideration. It is the role of the constituent materials in relation to the use of the goods that imparts the essential character. In this case, the function of the steel and zinc alloy supports provide structure to the feeder. The steel components also provide the greatest value and bulk to both bird feeders. Therefore, it is the opinion of this office that the steel components impart the essential character to both steel and plastic bird feeders.

We note that the Squirrel – X1 (#11) is composed of more than one metal. The hinged perch is comprised of zinc alloy. The port shield, cap, base, moving roof, slider bottom ring, end cap, and upper shield are all made of steel. Section XV, Note 7 of the HTSUS, states that the classification of articles of base metal containing two or more base metals are to be treated as articles of the base metal that predominates by weight over each of the other metals. Based on the information provided to our office, the metal in the bird feeder that predominates by weight is steel. Therefore, the Squirrel – X1 (#11) will be classified under heading 7323, HTSUS, which provides for household articles of iron or steel.

The applicable subheading for the Sweet Tweet Caf (#50216) and the Squirrel – X1 (#11) will be 7323.99.9080, HTSUS, which provides for “Table, kitchen or other household articles and parts thereof, of iron or steel…other, other, not coated or plated with precious metal, other, other, other.” The rate of duty will be 3.4 percent ad valorem.

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 on the World Wide Web at https://hts.usitc.gov/current.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 7323.99.9080, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 7323.99.9080, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china respectively.

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Dana L. Giammanco at dana.l.giammanco@cbp.dhs.gov.

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division

RE: The tariff classification of single and tandem supermarket checkout lane systems from China

This ruling is being issued in reply to your letter dated August 19, 2022, requesting the classification of two supermarket checkout lanes with conveyors. In lieu of samples, illustrative literature and product descriptions were provided.

The subject articles are described as a single supermarket checkout lane system (SKU# SAP-CL-300-SGL) and a tandem supermarket checkout lane system (SKU# SAP-CL-300-TDM). Each checkout lane system includes a conveyor unit (motor, controller, belt) in a large, floor-standing housing but does not include a computer, scale, or cash-handling equipment. The articles are made primarily of steel and stainless steel, although the list of materials include high density polypropylene panels with laminate sheets, powder coated milled steel and stainless-steel cladding panels, stainless-steel kick plates, a PC panel with electrical sockets, an aluminum 3-meter square tube, PVC plastic bumpers, acrylic LED signage with magnetic graphics, and PETG sneeze guards. The checkout lane systems are imported in multiple boxes on pallets but are essentially pre-assembled at the factory with minimal assembly required during installation. The single checkout lane system measures approximately 139″ (L) x 60″ (W) and the tandem checkout lane system measures approximately 169″ (L) x 87″ (W). They are made in China. See images below:

Single Checkout Lane System Tandem Checkout Lane System (SKU# SAP-CL-300-SGL) (SKU# SAP-CL-300-TDM)

Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is made in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes (together known as legal notes). If the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 are then applied in order.

In understanding the language of the HTSUS, the Explanatory Notes (ENs) of the Harmonized Commodity Description and coding System, which constitutes the official interpretation of the Harmonized System at the international level, may be utilized. The ENs, although not dispositive or legally binding, provide a commentary on the scope of each heading and are generally indicative of the proper interpretation of the HTSUS. The ENs to Chapter 94 of the HTSUS state, in relevant part, that the term “furniture” means: “(A): Any “movable” articles (not included under other more specific headings of the Nomenclature), which have the essential characteristic that they are constructed for placing on the floor or ground, and which are used, mainly with a utilitarian purpose, to equip private dwellings, hotels…. Similar articles (seats, chairs, etc.) for use in gardens, squares, promenades, etc., are included in this category.” The subject supermarket checkout lane systems meet this definition of furniture.

Although this office considered classification under HTSUS heading 8428 “Other lifting, handling, loading or unloading machinery…,” a 2014 World Customs Organization (WCO) Classification Opinion classified an essentially similar “checkout counter of aluminum, measuring 210 cm in length, featuring a conveyor belt and designed to house a cash register, of a kind used in shops and supermarkets” in subheading 9403.20, Harmonized Tariff Schedule. See image below:

Since the checkout lane systems are composed of different materials (metal, plastic, conveyor, electronics, etc.), they are considered composite goods for tariff purposes. The ENs to the HTSUS, 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. Upon review of relevant factors, this office finds that the metal components impart the essential character of the supermarket checkout lane systems.

By application of GRI 3(b), the applicable subheading for the single supermarket checkout lane system (SKU# SAP-CL-300-SGL) and the tandem supermarket checkout lane system (SKU# SAP-CL-300-TDM) will be subheading 9403.20.0086, HTSUS, which provides for “Other furniture and parts thereof: Other metal furniture: Other: Counters, lockers, racks, display cases, shelves, partitions and similar fixtures: Other.” The general rate of duty will be free.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9403.20.0086, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 9403.20.0086, HTSUS, listed above.

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 on the internet at https://hts.usitc.gov/current.

This ruling is being issued under the provisions of Part 177 of Title 19 of the Code of Federal Regulations (19 CFR Part 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, contact National Import Specialist Seth Mazze at seth.mazze@cbp.dhs.gov.

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division

RE: The tariff classification of birdfeeders from China

Dear Ms. Meagher:

In your letter dated August 25, 2022, on behalf of your client, Classic Brands LLC, you requested a tariff classification ruling. A breakdown of material sheets and photographs were submitted with your request. The importer’s website and samples were also reviewed. Samples have been previously sent back to you.

The items concerned are the Snacks’ N’ Treats Single Hanging Feeder (#38200), the Copper Acorn Tube (#38288) and the Grande Squirrel Resistant feeder (#50153) bird feeders. All three bird feeders are predominately made from plastic and steel components. The articles are designed for outdoor use.

The first item is referred to as the Snacks’ N’ Treats Single Hanging Feeder (38200). It is a black metal curved hanger with a hook at the top and a square open bottom. A blue plastic feeder dish is placed inside the open bottom insert. It measures approximately 6.5 inches long by 6.5 inches wide by 8.25 inches high. The item contains an acrylonitrile-butadiene-styrene (ABS) plastic material basin. The frame arm and frame hook are all steel. The feeder can hold approximately 0.8 pounds of seed.

The second item is referred to as the Copper Acorn Tube (#38288). It is a bronze cylindrical bird feeder that measures approximately 8 inches long by 8 inches wide by 12 inches high. The item contains a polyvinyl chloride (PVC) plastic 10-inch tube. A threaded perch and finial are made of aluminum. The four-inch tube locking ring, wire form retainer, roof, roof locator ring, threaded support post, hanger nut wire form, base locator ring, base, portal, port hood are made of steel.

The plastic feed tube contains a steel lid and a steel base. A flexible cable wire loop encased in plastic is attached to the top steel lid so the item can be hung. To fill the feeder with bird seed, the user would twist off the top and base and fill the feeder with seed. There are two ports where birds can perch on the feeder. The feeder can hold approximately 2.8 pounds of seed.

The third item is referred to as the Grande Squirrel Resistant Cage feeder (#50153). It is a bronze cylindrical bird feeder that measures approximately 10 inches long by 10 inches wide by 17 inches high. The feeder is squirrel resistant. The item contains a PVC plastic tube. The new base, portal, new roof, cage, top roof, deep wire form retainer, threaded rod, roof locking nut and oval ring are all steel.

The plastic feed tube is housed inside the steel cage feeder. A steel hook is attached to the top steel lid so the item can be hung. To fill the feeder with bird seed, the user would twist off the top and fill the feeder with seed. There are four ports where birds can perch on the feeder. The spring-loaded perch design shuts all ports simultaneously when the weight of a squirrel or larger bird is applied to the perches or lid. The feeder can hold approximately 3.1 pounds of seed.

You propose classification for the three bird feeders in subheading 3924.90.5650, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Tableware, kitchenware, other household articles and hygienic or toilet articles, of plastics: Other: Other. Other.” We disagree.

The steel and plastic bird feeders under consideration are both composite articles. The Snacks’ N’ Treats Single Hanging Feeder (#38200) is comprised of an ABS plastic material basin, a steel frame, and a steel hook. The Copper Acorn Tube (#38288) is comprised of a PVC 10-inch tube, an aluminum threaded perch, an aluminum finial, a four-inch steel tube locking ring, a steel wire form retainer, a steel roof, a steel roof locator ring, a steel threaded support post, a steel hanger nut wire form, a steel base locator ring, a steel base, a steel portal, and a steel port hood. The Grande Squirrel Resistant Cage feeder (#50153) is comprised of a PVC tube, a steel base, a steel portal, a steel roof, a steel cage, a steel top roof, a steel deep wire form retainer, a steel threaded rod, a steel roof locking nut, and an oval steel ring. The steel, aluminum, and plastic components are classified in different headings.

Classification of merchandise under the HTSUS is in accordance with the General Rules of Interpretation (GRIs) taken in order. GRI 1 provides that classification shall be determined according to the terms of the headings and any relative section or chapter notes. Since no one heading in the tariff schedule covers the steel, aluminum, and plastic components of the bird feeders in combination, GRI 1 cannot be used as a basis for classification. GRI 3(b) provides that mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale shall be classified as if they consisted of the material or component which gives them their essential character. As the steel, aluminum, and plastic bird feeders are composite goods, we must apply rule 3(b), which provides that composite goods are to be classified according to the component that gives the goods their essential character. EN VIII to GRI 3(b) explains that “the factor which determines essential character will vary as between different kinds of goods. It may, for example, be determined by the nature of the material or component, its bulk, quantity, weight, or the use of the goods.” We must determine whether the steel and aluminum supports, or the plastic components impart the essential character to the article under consideration. It is the role of the constituent materials in relation to the use of the goods that imparts the essential character. In this case, the function of the steel and aluminum supports provide structure to the feeder. The steel components also provide the greatest value and bulk to both bird feeders. Therefore, it is the opinion of this office that the steel components impart the essential character to both steel and plastic bird feeders.

We note that the Copper Acorn Tube (#38288) is composed of more than one metal. The four-inch tube locking ring, wire form retainer, roof, roof locator ring, threaded support post, hanger nut wire form, base locator ring, base, portal, port hood is made of steel. The threaded perch and finial are comprised of aluminum. Section XV, Note 7 of the HTSUS, states that the classification of articles of base metal containing two or more base metals are to be treated as articles of the base metal that predominates by weight over each of the other metals. Based on the information provided to our office, the metal in the bird feeder that predominates by weight is steel. Therefore, the Copper Acorn Tube (#38288) will be classified under heading 7323, HTSUS, which provides for household articles of iron or steel.

The applicable subheading for the Snacks’ N’ Treats Single Hanging Feeder (#38200), the Copper Acorn Tube (#38288), and the Grande Squirrel Resistant feeder (#50153) will be 7323.99.9080, HTSUS, which provides for “Table, kitchen or other household articles and parts thereof, of iron or steel…other, other, not coated or plated with precious metal, other, other, other.” The rate of duty will be 3.4 percent ad valorem.

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 on the World Wide Web at https://hts.usitc.gov/current.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 7323.99.9080, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 7323.99.9080, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china respectively.

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Dana L. Giammanco at dana.l.giammanco@cbp.dhs.gov.

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division

RE: The tariff classification of an eye mask, pillowcase, headband, and storage bag from China
In your letter dated August 10, 2022, you requested a tariff classification ruling on behalf of your client, QVC Inc. In lieu of samples, photographs were provided with your request.

Item #S 57839, described as a “Self-Care 19mm Silk Gift Set,” consists of an eye mask, pillowcase, headband, and storage bag imported and sold together as a set. The pillowcase and headband are made from 100 percent silk woven fabric, dyed white. The eye mask is made from 100 percent silk woven fabric, dyed grey. The storage bag is made from 100 percent polyester woven fabric, dyed white.

The padded eye mask measures approximately 8 x 3 inches and is stuffed with a thin layer of 100 percent polyester fiber fill. The mask features piping around the edges and an elastic band covered with self-fabric that allows the mask to be worn around the head. The eye mask is designed to shield the eyes from light.

The pillowcase, measuring 20 x 30 inches, is neither printed nor napped nor does it contain any embroidery, lace, braid, edging, trimming, piping, or applique work. It features a hidden, internal zipper closure along the side opening. The pillowcase is designed to fit over a standard sized bed pillow and protect the pillow from dust, dirt, and stains.

The headband encircles the head and features two 7 inch long and 3 inch wide pieces of fabric. The two pieces of fabric are looped together, and the ends are sewn to each end of a self-fabric covered seven-inch-long and two-inch-wide elastic band. The headband, designed to keep hair out of one’s face, is without any metal or wires.

The storage bag is an unlined pouch with a self-fabric tie closure. The hemmed pouch, measuring 12 x 7 inches, is used to store the eye mask, pillowcase, and headband when not in use.

General Rule of Interpretation (GRI) 3 provides for goods that are, prima facie, classifiable in two or more headings. GRI 3(b) provides that goods put up in sets for retail sale shall be classified as if they consisted of the material or component that gives them their essential character. According to the Explanatory Notes, the official interpretation of the Harmonized Tariff Schedule of the United States (HTSUS) at the international level, “goods put up in sets for retail sale” refers to 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; and (c) are put up in a manner suitable for sale directly to users without repackaging.

Although referred to as a set, the instant merchandise does not meet all of the qualifications of “goods put up in sets for retail sale.” The articles meet set criterion (a); that is, they “consist of at least two different articles which are, prima facie, classifiable in different headings.” However, although three of the articles can be used while sleeping, together, the items do not meet criterion (b); that is, they do not “consist of products or articles put together to meet a particular need or carry out a specific activity.” The eye mask is used to block out light while the user is resting or sleeping, the pillowcase is used to protect the pillow from dust, dirt and stains, the headband is used to hold the hair back and the bag is used to store the items when not being used. Additionally, since a sample or photograph of the items, in their imported condition, including packaging, was not provided, there is no way to verify that criterion (c) will be met. Since the subject merchandise fails to meet two of the GRI 3(b) set criteria, each article must be classified separately.

The applicable subheading for the eye mask and storage bag will be 6307.90.9891, HTSUS, which provides for “Other made up articles, including dress patterns: Other: Other: Other…Other: Other.” The rate of duty will be 7 percent ad valorem.

The applicable subheading for the pillowcase will be 6302.39.0020, HTSUS, which provides for “Bed linen, table linen, toilet linen and kitchen linen: other bed linen: of other textile materials… other: containing 85 percent or more by weight of silk or silk waste.” The duty rate will be 4.3 percent ad valorem.

The applicable subheading for the headband will be 6217.10.1010, HTSUS, which provides for “Other made up clothing accessories, containing 70 percent or more by weight of silk or silk waste, Headbands, ponytail holders and similar articles.” The duty rate will be 2.3 percent ad valorem.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 6217.10.1010, 6302.39.0020, and 6307.90.9891, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 6217.10.1010, 6302.39.0020, and 6307.90.9891, HTSUS, listed above.

The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.

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 on the World Wide Web at https://hts.usitc.gov/current.

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Kim Wachtel at kimberly.a.wachtel@cbp.dhs.gov.

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division

RE: The tariff classification of bird feeders from China

Dear Ms. Meagher:

In your letter dated August 24, 2022, on behalf of your client, Classic Brands LLC, you requested a tariff classification ruling. A breakdown of material sheets and photographs were submitted with your request. The importer’s website and samples were also reviewed. Samples have been previously sent back to you.

The five items concerned are the 12 SQU X-2, 105 SF Hopper, 13 SQU X-3, 106 SF X4, and 16 SQU X-6 bird feeders. All of the bird feeders are predominately made from plastic and steel components. The articles are designed for outdoor use.

The first item is referred to as the 12 SQU X-2. It is a brown cylindrical bird feeder that measures approximately 8 inches long by 11.25 inches wide by 11 inches high. The item contains a polystyrene plastic housing and a polypropylene plastic port shutter. The perch is made of zinc alloy. The port shield, actuator, baseplate, roof, and the roof hinge are all steel.

The plastic feed tube contains a steel lid and a steel base. A wire is attached to the top steel cap so the item can be hung. To fill the feeder with bird seed, the user lifts off the top steel cap. There are two ports where birds can perch on the feeder. The spring-loaded perch design shuts all ports simultaneously when the weight of a squirrel or larger bird is applied to the perches. The feeder is squirrel resistant and can hold approximately 4 pounds of seed.

The second item is referred to as the 105 SF Hopper. It is a bronze square bird feeder that measures approximately 8.5 inches long by 8.5 inches wide by 9 inches high. The item contains a polystyrene plastic clear panel, a polycarbonate plastic cap mount, a polypropylene plastic actuator. The cap is made of aluminum. The feeder base, perch, roof, side panel, assembly bracket and the panel retainer are all steel.

The plastic feed tube is housed inside the bird feeder. A wire is attached to the top steel lid so the item can be hung. To fill the feeder with bird seed, the user would press the push button to open up the top cap. There are four ports where birds can perch on the feeder. The feeder can hold approximately 3.6 pounds of seed.

The third item is referred to as the 13 SQU X-3. It is a bronze cylindrical bird feeder that measures approximately 6.75 inches long by 9.75 inches wide by 19 inches high. The item contains a hanger bar, roof lock, shutter, and a lock collar which are all made of polypropylene plastic. The tube is made of polycarbonate plastic. The hourglass perch is made of zinc alloy. The stamped band, roof, port cover bottom plate, diffuser port are all steel.

The plastic feed tube contains a steel lid and a steel base. A flexible cable wire loop encased in plastic is attached to the top steel cap so the item can be hung. To fill the feeder with bird seed, the user lifts off the top steel cap. There are two ports where birds can perch on the feeder. The spring-loaded perch design shuts all ports simultaneously when the weight of a squirrel or larger bird is applied to the perches. The feeder is squirrel resistant and can hold approximately 5 pounds of seed.

The fourth item is referred to as the 106 SF X4. It is a grey cylindrical bird feeder that measures approximately 5.5 inches long by 6.5 wide by 15.75 inches high. The item contains a polycarbonate plastic housing and a polypropylene plastic feeder button. The flip cap, mixed seed port, and tube cap are all aluminum. The base, base foot, and cage weldment are all steel.

The plastic feed tube is housed inside the bird feeder. A flexible cable wire loop encased in plastic is attached to the top steel lid so the item can be hung. To fill the feeder with bird seed, the user presses the button under the roof to open the cap. There are four ports where birds can perch on the feeder. The spring-loaded perch design shuts all ports simultaneously when the weight of a squirrel or larger bird is applied to the perches. The feeder is squirrel resistant and can hold approximately 1.5 pounds of seed.

The fifth item is referred to as the 16 SQU X-6. It is a bronze cylindrical bird feeder that measures approximately 6.9 inches long by 6.9 inches wide by 22 inches high. The item contains a port sleeve retainer, tension nut, adjustment nut sleeve, basin mount, seed funnel, tube lock ring, large capacity seed tube, cap lock, and a cap hanger bar that are all polycarbonate plastic. The cap bushing is made of nitrile shore rubber. The spring post and spring nut are all made of acetal plastic. The tube shield guard, the tube shield baffle, the metal basin, and cap are all aluminum. The port sleeve basin, perch ring weldment, port sleeve, compression spring, and hanger are all steel.

The plastic feed tube contains a steel lid and a steel base. A steel hanger is attached to the top steel cap so the item can be hung. To fill the feeder with bird seed, the user lifts off the top steel cap. There are six ports where birds can perch on the feeder. The spring-loaded perch design shuts all ports simultaneously when the weight of a squirrel or larger bird is applied to the perches. The feeder is squirrel resistant and can hold approximately 6.1 pounds of seed.

You propose classification for all five bird feeders in subheading 3924.90.5650, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Tableware, kitchenware, other household articles and hygienic or toilet articles, of plastics: Other: Other. Other.” We disagree.

The steel and plastic bird feeders under consideration are both composite articles. 12 SQU X-2 is comprised of a polystyrene plastic housing, a polypropylene plastic port shutter, a zinc alloy perch, a steel port shield, a steel actuator, a steel baseplate, a steel roof, and a steel roof hinge. 105 SF Hopper is comprised of a polystyrene plastic clear panel, a polycarbonate plastic cap mount, a polypropylene plastic actuator, an aluminum cap, a steel feeder base, a steel perch, a steel roof, a steel side panel, a steel assembly bracket and a steel panel retainer. 13 SQU X-3 is comprised of a hanger bar, roof lock, shutter, and a lock collar which are all made of polypropylene plastic. A polycarbonate plastic tube, a zinc alloy hourglass perch, a steel stamped band, a steel roof, a steel port cover bottom plate, a steel diffuser port. 106 SF X4 is comprised of a polycarbonate plastic housing and a polypropylene plastic feeder button. An aluminum flip cap, an aluminum mixed seed port, and an aluminum tube cap, a steel base foot, a steel cage weldment, and a steel base. 16 SQU X-6 is comprised of a port sleeve retainer, tension nut, adjustment nut sleeve, basin mount, seed funnel, tube lock ring, large capacity seed tube, cap lock, and a cap hanger bar that are all made of polycarbonate plastic. The cap bushing is made of nitrile shore rubber. The spring post and plastic spring nut are made of acetal plastic. The metal basin, cap, tube shield guard and the tube shield baffle are all made of aluminum. The port sleeve basin, perch ring weldment, port sleeve, compression spring, and hanger are all made of steel. The steel, aluminum, zinc alloy, rubber, and plastic components are classified in different headings.

Classification of merchandise under the HTSUS is in accordance with the General Rules of Interpretation (GRIs) taken in order. GRI 1 provides that classification shall be determined according to the terms of the headings and any relative section or chapter notes. Since no one heading in the tariff schedule covers the steel, aluminum, zinc alloy, rubber, and plastic components of the bird feeders in combination, GRI 1 cannot be used as a basis for classification. GRI 3(b) provides that mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale shall be classified as if they consisted of the material or component which gives them their essential character. As the steel, aluminum, zinc alloy, rubber, and plastic bird feeders are composite goods, we must apply rule 3(b), which provides that composite goods are to be classified according to the component that gives the goods their essential character.

EN VIII to GRI 3(b) explains that “the factor which determines essential character will vary as between different kinds of goods. It may, for example, be determined by the nature of the material or component, its bulk, quantity, weight or the use of the goods.” We must determine whether the steel, aluminum, and zinc alloy supports, or the plastic components impart the essential character to the article under consideration. It is the role of the constituent materials in relation to the use of the goods that imparts the essential character. In this case, the function of the steel, aluminum, and zinc alloy supports provide structure to the feeder. The steel components also provide the greatest value and bulk to all of the bird feeders. Therefore, it is the opinion of this office that the steel components impart the essential character to all of the steel and plastic bird feeders.

We note that 12 SQU X-2, 105 SF Hopper, 13 SQU X-3, 106 SF X4, and 16 SQU X-6 are composed of more than one metal. 12 SQU X2, the port shield, actuator, baseplate, roof and roof hinge are all comprised of steel. The perch is made of zinc alloy. 105 SF Hopper, the feeder base, perch, roof, side panel, assembly bracket and panel retainer are all comprised of steel. The cap is made of aluminum. 13 SQU X-3, the stamped band, roof, port cover, bottom plate, diffuser port are all comprised of steel. The hourglass perch is made of zinc alloy. 106 SF X4, the base, base foot, and cage weldment are all comprised of steel. The flip cap, mixed seed port, and tube cap are made of aluminum. 16 SQU X-6, the basin, cap, tube shield guard, and the tube shield baffle are all made of aluminum. The port sleeve basin, perch ring weldment, port sleeve, compression spring, and hanger are all made of steel. Section XV, Note 7 of the HTSUS, states that the classification of articles of base metal containing two or more base metals are to be treated as articles of the base metal that predominates by weight over each of the other metals. Based on the information provided to our office, the metal in the bird feeders that predominates by weight is steel. Therefore, the 12 SQU X-2, 105 SF Hopper, 13 SQU X-3, 106 SF X4, and 16 SQUX-6 will be classified under heading 7323, HTSUS, which provides for household articles of iron or steel.

The applicable subheading for the 12 SQU X-2, 105 SF Hopper, 13 SQU X-3, 106 SF X4, and 16 SQU X-6 will be 7323.99.9080, HTSUS, which provides for “Table, kitchen or other household articles and parts thereof, of iron or steel…other, other, not coated or plated with precious metal, other, other, other.” The rate of duty will be 3.4 percent ad valorem.

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 on the World Wide Web at https://hts.usitc.gov/current.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 7323.99.9080, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 7323.99.9080, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china respectively.

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Dana L. Giammanco at dana.l.giammanco@cbp.dhs.gov.

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division

RE: The tariff classification of a tape and dispenser set from China.
In your letter dated August 24, 2022, you requested a tariff classification ruling. A sample of the product was sent to our office and will be returned.

The item under consideration is described as a tape and dispenser set, which includes two rolls of heavy-duty tape along with a tape dispenser. The items are packaged together and imported under item number 7063910. The heavy-duty tape measures 1.89 inches x 70.8 yards and is used for sealing shipping packages. The tape dispenser is made of metal with a plastic handle, adjustable tension brake for easy dispensing and a blade that cuts through tape for removal.

General Rule of Interpretation (GRI) 1, of the 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 and any relative section or chapter notes. Goods that are, prima facie, classifiable under two or more headings, are classifiable in accordance with GRI 3, HTSUS. GRI 3(a) states in part that when two or more headings each refer to part only of the items in a set put up for retail sale, those headings are to be regarded as equally specific, even if one heading gives a more precise description of the good.

The instant good consists of at least two different articles that are, prima facie, classifiable in different subheadings, the tape in heading 3919, HTSUS, and the dispenser in heading 8422, HTSUS. It consists of articles put up together to carry out a specific activity (i.e., sealing packages). Finally, the articles are put up in a manner suitable for sale directly to users without repacking. Therefore, the good in question is within the term “goods put up in sets for retail sale.” GRI 3(b) states in part that goods put up in sets for retail sale, which cannot be classified by reference to 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 essential character of this set is imparted by the dispenser.

In your letter, you suggest the classification for the rolls of tape to be in subheading 3919.10.2055, HTSUS. If the rolls of tape were imported separately, this would be the correct classification. However, the tape dispenser and rolls of tape are packaged together and put up for retail sale at the time of importation, constituting a set in accordance with GRI 3(b). Therefore, the tape will not be classified separately.

Accordingly, the applicable subheading for the tape and dispenser set, item 7063910, will be 8422.30.9191 Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Dishwashing machines; machinery for cleaning or drying bottles or other containers; machinery for filling, closing, sealing or labeling bottles, cans, boxes, bags or other containers; machinery for capsuling bottles, jars, tubes and similar containers; other packing or wrapping machinery (including heat-shrink wrapping machinery); machinery for aerating beverages; parts thereof: Machinery for filling, closing, sealing or labeling bottles, cans, boxes, bags or other containers; machinery for capsuling bottles, jars, tubes and similar containers; machinery for aerating beverages: Other: Machinery for filling, closing, sealing, capsuling or labeling boxes, bags or similar containers: Other”. The rate of duty will be free.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8422.30.9191, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01, in addition to subheading 8422.30.9191, HTSUS, listed above.

The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china respectively.

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 on the World Wide Web at https://hts.usitc.gov/current.

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Jason Christie at jason.m.christie@cbp.dhs.gov.

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division

RE: The tariff classification of Tuna Bowls from Thailand

In your letter dated August 5, 2022, you requested a tariff classification ruling on behalf of your client, Tri-Union Seafoods, LLC dba Chicken of The Sea International (El Segundo, CA).

The subject merchandise referred to as Tuna Bowls is composed of two bowls per kit, with one containing tuna and the other containing rice along with other flavoring ingredients. Three such kits are under consideration here, as follows:

Teriyaki Tuna Bowl with White Rice: The item consists of, in descending percentages of quantity, white rice, skipjack tuna, water, soy sauce, sugar, red bell pepper, modified food starch, salt, ginger, rice bran oil, guar gum, vinegar, spices, and garlic.

Lemon and Ginger Sesame Tuna Bowl with White Rice: The item consists of, in descending percentages of quantity, white rice, skipjack tuna, water, sugar, soy sauce, vinegar, ginger, white sesame, modified food starch, rice bran oil, salt, vegetable juice concentrate, guar gum, garlic powder, citric acid, sesame oil, caramel color, oleoresin paprika, and lemon flavor.

Sweet and Spicy Tuna Bowl with White Rice: The item consists of, in descending percentages of quantity, white rice, skipjack tuna, water, red bell pepper, sugar, vinegar, onion, garlic, tomato, rice bran oil, tomato paste, modified food starch, salt, yeast extract, paprika powder, guar gum, and spices. The idea behind the Tuna Bowls is to create a complete meal ready to heat and serve. The two bowls in each kit are designed to be heated together in a microwave oven, after which the tuna is to be deposited in the bowl of rice and stirred to combine the ingredients for consumption.

The Tuna Bowls are a set comprised of components that are classifiable in different tariff headings. Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) occurs in accordance with the General Rules of Interpretation (GRIs) taken in order. GRI 3(b) of the HTSUS provides, in relevant part, that sets which cannot be classified by reference to GRI 3(a) shall be classified as if they consisted of the material or component which gives them their essential character. The protein in this case, the tuna, imparts the essential character to the Tuna Bowls under review.

The applicable subheading for the Tuna Bowls will be 1604.20.0510, HTSUS, which provides for, “Prepared or preserved fish; caviar and caviar substitutes prepared from fish eggs, other prepared or preserved fish, products containing meat of crustaceans, molluscs or other aquatic invertebrates; prepared meals, prepared meals.” The rate of duty will be 5 percent ad valorem.

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 on the World Wide Web at https://hts.usitc.gov/current.

This merchandise is subject to The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act), which is regulated by the Food and Drug Administration (FDA). Information on the Bioterrorism Act can be obtained by calling the FDA at 301.575.0156, or at the Web site www.fda.gov/oc/bioterrorism/bioact.html.

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Ekeng Manczuk at ekeng.b.manczuk@cbp.dhs.gov.

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division

RE: The tariff classification of decorative pumpkin figures from China

In your letter, dated August 25, 2022, you requested a tariff classification ruling. Photos and detailed descriptions were submitted for our review in lieu of samples.

The items under consideration are three decorative pumpkin figures, in multiple sizes, that will be sold individually or packaged together in various configurations for retail sale. The pumpkins are constructed of a polyfoam core that is overlaid with various materials. One is covered with slices of wood chips (jujube tree); one is covered with strands of twisted corn husk; and the remaining one is covered with braided cattail. The stems are constructed of twigs, corn husk or cattail respectively. The pumpkins will be imported in three sizes: Large pumpkins, measuring approximately 9.2 inches high by 8.5 inches in diameter; Medium pumpkins, measuring approximately 7.10 inches high by 6.5 inches in diameter, and Small pumpkins, measuring approximately 4.98 inches high by 4.5 inches in diameter.

You state that you plan to import the pumpkins in the following retail pack combinations:

Item 1: 2 Large corn husk pumpkins Item 2: 1 Large wood chip pumpkin Item 3: 2 Medium pumpkins – 1 corn husk and 1 wood chip Item 4: 2 Medium pumpkins – 1 corn husk and 1 cattail Item 5: 3 Small pumpkins – 1 corn husk and 2 wood chip Item 6: 3 Small pumpkins – 1 corn husk and 2 cattail

The classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is governed by the General Rules of Interpretation (“GRIs”), taken in order. GRI 1 requires that classification be determined according to the terms of the headings and any relative section or chapter notes. In the event that goods cannot be classified solely on the basis of GRI 1, and if the heading and legal notes do not otherwise require, the remaining GRIs will be applied, in the order of their appearance. For the instant item, neither GRI 1 nor GRI 2 is applicable.

Because the materials (i.e., polyfoam and wood slices, cornhusks, or cattail) from which the samples are constructed are prima facie classifiable in different headings, the figures are composite goods within the meaning of General Rule of Interpretation (GRI) 3(b). GRI 3(b) states, in pertinent part:

(b) Mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale, which cannot be classified by reference to 3(a), shall be classified as if they consisted of the material or component which gives them their essential character, insofar as this criterion is applicable.

In accordance with the Explanatory Notes (ENs) for GRI 3(b), the essential character of an item may be determined by the nature of the material or component, its bulk, quantity, weight, or value, or by the role of a constituent material in relation to the use of the goods.

While the polyfoam provides the structure of the pumpkin figures, Customs Headquarters instructs in rulings HQ W968064 and W968066 that, for such foam figures, it is not the structural material, but the covering decorative material that imparts the article’s essential character. In this case, the wood chips, corn husks, and cattail.

The twisted corn husk strips and braided cattail constitute “plaiting materials” as set forth in Chapter Note 1 of Chapter 46, HTSUS, which states as follows:

In this chapter the expression “plaiting materials” means materials in a state or form suitable for plaiting, interlacing or similar processes; it includes straw, osier or willow, bamboos, rattans, rushes, reeds, strips of wood, strips of other vegetable material (for example, strips of bark, narrow leaves and raffia or other strips obtained from broad leaves), unspun natural textile fibers, monofilament and strip and the like of plastics and strips of paper, but not strips of leather or composition leather or of felt or nonwovens, human hair, horsehair, textile rovings or yarns, or monofilament and strip and the like of chapter 54.

The applicable subheading for the corn husk pumpkins and cattail pumpkins, imported separately or in packs with each other (Items 1, 4 and 6), will be 4602.19.8000, HTSUS, which provides for Basketwork, wickerwork and other articles, made directly to shape from plaiting materials or made up from articles of heading 4601; Of vegetable materials: Other: Other: Other: Other: Other. The rate of duty will be 2.3 percent ad valorem.

The applicable subheading for the wood chip pumpkins, imported separately (Item 2), will be 4420.19.0000, HTSUS, which provides for Statuettes and other ornaments, of wood: Other. The rate of duty will be 3.2 percent ad valorem.

The remaining Items 3 and 5 constitute “sets” for customs purposes. EN X to GRI 3(b) provides: “for the purposes of this Rule, the term “goods put up in sets for retail sale” shall be taken to mean 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 together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without repacking (e.g., in boxes or cases or on boards).” Sets are classified according to the component, or components taken together, which can be regarded as conferring on the set as a whole its essential character. GRI 3(c) provides that when goods cannot be classified by reference to GRI 3(a) or GRI 3(b), they are classified in the heading that occurs last in numerical order among those which equally merit consideration.

Item 5 consists of a set of two wood chip pumpkins and one corn husk pumpkin of equal size packaged together for retail sale. You further state that the pumpkins are of equal value regardless of outer material. Therefore, we conclude that the wood chip pumpkins impart the essential character of the set by quantity (two of them vs. just one corn husk pumpkin).

The applicable subheading for Item 5 will be 4420.19.0000, HTSUS, which provides for Statuettes and other ornaments, of wood: Other. The rate of duty will be 3.2 percent ad valorem.

Item 3 consists of a set with one medium corn husk pumpkin packaged with one medium wood chip pumpkin. In this scenario neither pumpkin predominates by value, bulk, quantity, use etc. Therefore, this set is classified in the heading that occurs last in numerical order among those which equally merit consideration, per GRI 3(c).

The applicable subheading for Item 3 will be 4602.19.8000, HTSUS, which provides for Basketwork, wickerwork and other articles, made directly to shape from plaiting materials or made up from articles of heading 4601; Of vegetable materials: Other: Other: Other: Other: Other. The rate of duty will be 2.3 percent ad valorem.

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 on the World Wide Web at https://hts.usitc.gov/current.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 4602.19.8000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, 9903.88.03, in addition to subheading 4602.19.8000, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.

The importation of this product may be subject to import regulations administered by the U.S. Department of Agriculture (U.S.D.A.). Information regarding applicable regulations administered by the U.S.D.A. may be addressed to that agency at the following location:

U.S. Department of Agriculture A.P.H.I.S., PPQ 4700 River Road, Unit 136 Riverdale, MD 20737

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Charlene Miller at charlene.s.miller@cbp.dhs.gov.

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division

RE: The tariff classification of a harvest wall decoration from China.

In your letter dated August 19, 2022, you requested a tariff classification ruling.

An image was submitted in lieu of a sample.

The product under consideration is described as the “Harvest Wall Dcor with Floral.” It consists of multiple components. The white backing is in the appearance of a window frame and is made of medium density fiberboard (MDF). It features a jute rope at the top to hang the decoration from the wall. Attached across the bottom of the window frame are four MDF squares in a natural wood color, each with a white letter printed on it to spell out the word “FALL.” Affixed to the front of the window frame is a wreath made from artificial foliage in fall coloration that has a mostly obscured natural vine core. Per your submission, the leaves are made from polyester fabric and the pumpkins are polystyrene plastic foam. The wreath is constructed with the use of wire and adhesive. The product measures 18.11 inches (length) by 2.95 inches (width) by 11.61 inches (height).

In your request, you proposed subheading 4420.19.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for statuettes and other ornaments of wood. We disagree. While the wooden pieces do predominate by weight and value over the other components, we cannot discount the visual impact of the wreath in relation to the wooden elements. As such, we hold the opinion that these decorative elements all merit equal consideration and the wreath, which meets the requirements set forth by heading 6702, would come last in tariff, General Rule of Interpretation (GRI) 3(c) noted.

Within heading 6702, it is the polyester fabric leaves that would impart the essential character to the wreath, GRI 6 and 3(b) noted.

The applicable subheading for the “Harvest Wall Dcor with Floral” will be 6702.90.3500, HTSUS, which provides for “[a]rtificial flowers, foliage and fruit and parts thereof; articles made of artificial flowers, foliage or fruit: [o]f other materials: [o]ther: [o]f man-made fibers.” The column one, general rate of duty is 9 percent ad valorem.

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/current.

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Kristopher Burton at kristopher.burton@cbp.dhs.gov.

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division

RE: The tariff classification of a child-size office cubicle comprised of a desk with attached walls and a built-in shelf, an under-desk cabinet, and a water dispenser from China
This ruling is being issued in reply to your letter dated August 22, 2022, requesting a ruling on the classification of the “Little Tikes My First Cubicle,” item #663796, a child-size office cubicle that includes a desk with attached walls and a built-in shelf, a 3-drawer under-desk cabinet, and a non-electric gravity-fed functional water dispenser. The desk with walls and shelf and the cabinet are made of medium density fiberboard (MDF). The water dispenser is made of plastic. In lieu of samples, illustrative literature and product descriptions were provided.

The “L”-shaped cubicle desk measures approximately 47″ (W) x 47″ (W) x 16″ (D) x 21″ (H). The two large cubicle walls measure approximately 48″ (W) x 39″ (H) and the two small cubicle walls measure approximately 18″ (W) x 39″ (H). The 3-drawer under-desk cabinet measures approximately 12″ (W) x 15″ (D) x 19″ (H). Although the water dispenser has blue and red spigots, it does not use electricity or otherwise heat the water. It measures 11″ (W) x 11″ (D) x 20″ (H).

Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is made in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes (together known as legal notes). If the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 are then applied in order.

A “set” is defined within the meaning of GRI 3(b) and the Explanatory Notes (ENs) to the HTSUS, which constitute the official interpretation of the tariff at the international level. EN X to GRI 3(b) provides that “[f]or the purposes of this Rule, the term “goods put up in sets for retail sale” shall be taken to mean 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 together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without repacking (e.g., in boxes or cases or on boards).” Sets are classified according to the component, or components taken together, which can be regarded as conferring on the set as a whole its essential character.

Although the articles meet GRI 3(b) set criteria (a) and (c), they do not meet criterion (b) because the three items-the desk with attached walls and shelf, the under-desk cabinet and the water dispenser-do not meet a particular need or carry out a specific activity. Since the three articles fail to meet all three GRI 3(b) set criteria, each article must be classified separately.

In understanding the language of the HTSUS, the ENs of the Harmonized Commodity Description and Coding System, which constitutes the official interpretation of the Harmonized System at the international level, may be utilized. The ENs, although not dispositive or legally binding, provide a commentary on the scope of each heading and are generally indicative of the proper interpretation of the HTSUS. The ENs to Chapter 94 of the HTSUS state, in relevant part, that the term “furniture” means: “(A): Any “movable” articles (not included under other more specific headings of the Nomenclature), which have the essential characteristic that they are constructed for placing on the floor or ground, and which are used, mainly with a utilitarian purpose, to equip private dwellings, hotels…. Similar articles (seats, chairs, etc.) for use in gardens, squares, promenades, etc., are included in this category.” The subject desk with walls and shelf, and the 3-drawer under-desk cabinet meet this definition of furniture.

The applicable subheading for the “Little Tikes My First Cubicle,” item #663796, with the exception of the water dispenser, will be subheading 9403.60.8081, HTSUS, which provides for “Other furniture and parts thereof: Other wooden furniture: Other: Other.” The general rate of duty will be free.

Since the water dispenser will be considered an article of plastic, and since it is not more specifically provided for elsewhere, the applicable subheading will be 3926.90.9985, HTSUS, which provides for “Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Other: Other.” The general rate of duty will be 5.3 percent ad valorem.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9403.60.8081, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 9403.60.8081, HTSUS, listed above.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 3926.90.9985, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 3926.90.9985, HTSUS, listed above.

The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.

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 on the internet at https://hts.usitc.gov/current.

This ruling is being issued under the provisions of Part 177 of Title 19 of the Code of Federal Regulations (19 CFR Part 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 desk and cabinet, contact National Import Specialist Seth Mazze at seth.mazze@cbp.dhs.gov. If you have any questions regarding the water dispenser, contact National Import Specialist Kristopher Burton at kristopher.burton@cbp.dhs.gov.

Sincerely,

Steven A. Mack
Director

National Commodity Specialist Division

Source US Customs

 

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