CLA-2-96:OT:RR:NC:N4 462
Joanne Jordan
Hankscraft Inc
300 Wengel Drive Reedsburg, WI 53959
RE: The tariff classification of pet grooming tools from China
Dear Ms. Jordan:
In your letter dated November 8, 2024, you requested a tariff classification ruling. Photos and product descriptions were submitted for review.
The first product is described as the “Furminator Cat Undercoat Small Size Short Hair,” item number T691659. This article is a de-shedding tool for grooming cats. It features a stainless steel de-shedding comb, an ergonomic handle, and a button that releases the fur. You suggest that this de-shedding tool is classifiable in 9615.19.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Combs, hair-slides and the like: hairpins, curling pins, curling grips, hair-curlers and the like, other than those of heading 8516, and parts thereof: Combs, hair-slides and the like: Other: Combs: Valued over $4.50 per gross." We agree with this suggestion.
The second product is described as the “Furminator Dog and Cat Dual Brush,” item number T691663. This is a grooming brush for grooming dogs and cats. It is comprised of a brush with metal bristles on one side and boar's hair bristles on the other side. You suggest that this brush is also classifiable under 9615.19.4000, HTSUS. We disagree. This brush is more specifically provided for in 9603.90.8050, HTSUS, which includes “brooms, brushes (including brushes constituting parts of machines, appliances or vehicles), hand-operated mechanical floor sweepers, not motorized, mops and feather dusters; prepared knots and tufts for broom or brush making; paint pads and rollers; squeegees (other than roller squeegees): Other: Other: Other.”
The third product is described as the “Furminator Dog and Cat Nail Clipper,” item number T691751. This article is a grooming tool designed for trimming a dog or cat’s claws and features stainless-steel cutting edges with a nail guide. We find it to be similar to the pet nail clipper described in N299953, dated August 23, 2018, and we will classify this in the same manner.
The applicable subheading for the “Furminator Cat Undercoat Small Size Short Hair,” item number T691659 will be 9615.19.4000, HTSUS, which provides for "Combs, hair-slides and the like: hairpins, curling pins, curling grips, hair-curlers and the like, other than those of heading 8516, and parts thereof: Combs, hair-slides and the like: Other: Combs: Valued over $4.50 per gross." The rate of duty will be 28.8 cents per gross plus 4.6% ad valorem.
The applicable subheading for the “Furminator Dog and Cat Dual Brush,” item number T691663 will be 9603.90.8050, HTSUS, which provides for “brooms, brushes (including brushes constituting parts of machines, appliances or vehicles), hand-operated mechanical floor sweepers, not motorized, mops and feather dusters; prepared knots and tufts for broom or brush making; paint pads and rollers; squeegees (other than roller squeegees): Other: Other: Other.” The rate of duty will be 2.8% ad valorem.
The applicable subheading for the “Furminator Dog and Cat Nail Clipper,” item number T691751, will be 8214.20.3000, HTSUS, which provides for “other articles of cutlery (for example, hair clippers, butchers' or kitchen cleavers, chopping or mincing knives, paper knives); manicure or pedicure sets and instruments (including nail files); base metal parts thereof: manicure or pedicure sets and instruments (including nail files), and parts thereof: cuticle or corn knives, cuticle pushers, nail files, nail cleaners, nail nippers and clippers, all the foregoing used for manicure or pedicure purposes, and parts thereof.” The rate of duty is 4 percent ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9603.90.8050, 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 9603.90.8050, 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/programs-administration/trade-remedies, 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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Sandra Sary at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division