CLA-2-66:OT:RR:NC:4:434
James Herring
Brellas n Fans
201 Bay Shore Ave.
Long Beach, CA 90803
RE: The tariff classification of umbrellas from Thailand
Dear Mr. Herring:
In your letter, dated February 21, 2025, you requested a tariff classification ruling on several styles of umbrellas. In lieu of samples, a detailed description and photos were submitted for our review.
The products under consideration are umbrellas, in various styles. Most measure 2.5’ across the open canopy and have 28” shafts with handles. Some are also offered in sizes for children that measure 1.5’ across and have 20” shafts with handles. The shafts are not telescoping.
“Item 1” is a hand-held, collapsible sun umbrella with a cotton canvas canopy and bamboo frame and shaft.
“Item 2” is a hand-held, collapsible sun umbrella with a printed paper canopy and bamboo frame and shaft.
“Item 3” are several styles of hand-held, collapsible umbrellas of various canopy materials (rayon, cotton canvas, paper) with bamboo shafts and frames. All are hand painted with intricate designs, such as flowers or birds. Those painted on cotton with oil paints can withstand rain, while the others painted with acrylic paint are only suitable as sun umbrellas.
You propose classification of the Item 3, hand painted umbrellas, in subheading 9701.10.0000 Harmonized Tariff Schedule of the United States (HTSUS). Subheading 9701.10.0000 HTSUS expired at the end of calendar year 2021. The new statistical suffix equivalent for 2022 and forward is 9701.99.0000 which provides for “Painting, drawings and pastels, executed entirely by hand, other than drawings of heading 4906 and other than hand-painted or hand-decorated manufactured articles; collages, mosaics and similar decorative plaques: Other: Other.” The subject goods are hand-painted or hand-decorated manufactured articles and works of conventional craftsmanship of a commercial character, even if they are designed or created by artists. Classification in subheading 9701.99.0000, HTSUS, is precluded.
The applicable subheading for all styles of the umbrellas will be 6601.99.0000, HTSUS, which provides for “Umbrellas and sun umbrellas (including walking-stick umbrellas, garden umbrellas and similar umbrellas): Other: Other.” The column one, general rate of duty will be 8.2 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.
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 Regulations (19 CFR 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 [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division