CLA-2-94:OT:RR:NC:N4:463

Angelica Jimenez
PMK Internal LLC
18900 8th Avenue South
Sea Tac, WA 98148

RE: The classification of pocket coil mattress cores from Mexico

Dear Ms. Jimenez:

This ruling is being issued in response to your letter dated May 6, 2024, requesting a tariff classification determination on behalf of your client, Kuka Sleep Inc. In lieu of samples, pictures and a product description were provided.

Based upon the provided information and subsequent communications, the subject articles are identified as pocket coil mattress springs. They will be made from steel wire with diameters ranging from 1.6 mm to 2.3 mm, sealed in individual non-woven fabric pockets, glued together to form rectangular mattress cores and covered, top and bottom, with a non-woven fabric. They are made in Mexico and will be produced in the following 10 sizes: |Item |Item Numbers |Dimensions (approximate W x L x D) |Pocket Coils | |1 | 02.15.01052 |29.9" x 65.7" x 7.1" |312 | |2 |02.15.01053 |29.9" x 70.5" x 7.1" |336 | |3 |02.15.01790 |30.3" x 71.3" x 5.5" |336 | |4 |02.15.01054 |44.9" x 65.7" x 7.1" |468 | |5 |02.15.01055 |51.2" x 70.5" x 7.1" |560 | |6 |02.15.01875 |37.6" x 75" x 7.9" |450 | |7 |02.15.01877 |53.5" x 75" x 7.9" |630 | |8 |02.15.01946 |60.2" x 80.3" x 8.7" |768 | |9 |02.15.01614 |29.9" x 79.7" x 7.1" |384 | |10 |02.15.01756 |35.4" x 83.7" x 7.1" |476 |

See image below:

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. If the goods cannot be classified solely based on GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may then be applied in order.

Based on the aforementioned information, the applicable classification for items 6, 7, and 8 in the table above will be subheading 9404.29.9013, HTSUS, which provides for "Mattress supports; articles of bedding and similar furnishing (for example, mattresses, quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed or internally fitted with any material or of cellular rubber or plastics, whether or not covered: Mattresses: Of other materials: Other: Uncovered innerspring units: Of a width exceeding 91 cm, of a length exceeding 184 cm, and of a depth exceeding 8 cm." The general rate of duty will be 6 percent ad valorem.

Based on the aforementioned information, the applicable classification for items 1 through 5 and 9 and 10 in the table above will be subheading 9404.29.9050, HTSUS, which provides for "Mattress supports; articles of bedding and similar furnishing (for example, mattresses, quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed or internally fitted with any material or of cellular rubber or plastics, whether or not covered: Mattresses: Of other materials: Other: Uncovered innerspring units: Other." The general rate of duty will be 6 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 internet at https://hts.usitc.gov/current.

The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is 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. If the facts are modified in any way, or if the goods do not conform to these facts at the time of importation, you should bring this to the attention of 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 Title 19 of the Code of Federal Regulations (19 C.F.R. 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 [email protected].

Sincerely,


Steven A. Mack
Director
National Commodity Specialist Division