CLA-2-63:OT:RR:NC:N2:349

Mr. Riley Tsunoda
Jarl Voss LLC
301 Riverdale Drive, Apt 14 Rocky River, OH 44116

RE:  The tariff classification of a kitchen dish drying and appliance mat from China

Dear Mr. Tsunoda:

In your letter dated December 18, 2024, you requested a tariff classification ruling for a kitchen dish drying and appliance mat.  In lieu of a sample, photographs were submitted with your request.

Item# JV-1145-03 Burlap is a dish drying and appliance counter mat designed to be used in the kitchen or bathroom to protect countertop surfaces from water and moisture.  You state it can also be used under appliances and storage containers to protect surfaces from heat, spills, and scratches.  The mat is constructed of woven jute burlap fabric laminated to a backing of vulcanized rubber and is printed on the bottom right corner with the name “Ternal” and its logo.  The finished mat has rounded corners and measures 12 × 19 inches.  You state that the mat may be sold individually or in sets and is packaged for retail sale in protective plastic.

The applicable subheading for the kitchen dish drying and appliance mat, Item# JV-1145-03 Burlap, will be 6304.99.3500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other furnishing articles, excluding those of heading 9404: Other: Not knitted or crocheted, of other textile materials: Other: Other.” The rate of duty will be 11.3 percent ad valorem.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 6304.99.3500, 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 6304.99.3500, 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 Kim Wachtel at [email protected].


Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division