CLA-2-44:OT:RR:NC:4:434
Logan Frank Bunzl Retail Services 8338 Austin Ave. Morton Grove, IL 60053 RE: The tariff classification of clothes hangers from China Dear Mr. Frank: In your letter, dated March 13, 2025, you requested a tariff classification ruling for five styles of clothes hangers. In lieu of samples, photos and detailed descriptions were submitted for our review. Item 1 is a hanger designed to hold both an upper body garment and a lower body garment simultaneously, for example a suit jacket and pants. The hanger is made primarily of wood with a top section that slopes down on each side and is notched near each end, and a metal top hook. Suspended with metal fasteners across the bottom is a wooden rod to fold pants over. You state that the wood portions make up approximately 75 percent of the cost and weight of the finished hanger. Item 2 is a hanger designed to hold pants. A wooden horizontal cross piece with a wire top hook suspends a parallel wooden rod a couple of inches below. Metal wire connects the pieces. Per your submission, the wooden elements make up approximately 70 percent of the cost and weight of the finished hanger. Item 3 is a hanger designed to hold both an upper body garment and a lower body garment simultaneously. As with Item 1, the hanger is made of a wooden top portion that slopes down on each side and is notched near the ends. A horizonal metal bar with two metal clips is attached below to clip a skirt or pants. Per your submission, the wood accounts for approximately 65 percent of the cost and weight of the finished hanger. Item 4 consists of a wooden horizontal cross piece with a wire top hook. A metal wire is attached that runs parallel to the wooden piece a couple of inches below and has two metal clips attached to hold a skirt or pants. You state that the wooden elements make up approximately 50 percent of the cost and 55 percent of the weight of the finished hangers. The remainder of the cost and weight is the metal components.
Item 5 resembles Item 4, except the clips are plastic. Per your submission, the wood makes up approximately 55 percent of the cost and weight of the finished hanger, the metal makes up approximately 25 percent, and the plastic makes up the remaining 20 percent. You propose classification of the hangers in subheading 4421.10.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for, “Other articles of wood: Clothes hangers.” The hangers are composite articles made of wood, metal, and in the case of item 5, some plastic. Classification of merchandise under the HTSUS is in accordance with the General Rules of Interpretation (GRIs). GRI 3(b) provides that composite articles consisting of different materials or made up of different components 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. In the case of Items 1, 2, and 3, we agree that the wood is the most essential component in terms of role and also predominates by weight and cost. For Item 4, the wood again predominates by weight and plays an indispensable part in the construction of the hanger. The wood, therefore, imparts the essential character. For Item 5, The roles of the materials are more equal, but, as the wood predominates by cost and weight, we find that the wood imparts the essential character. The applicable subheading for the five styles of hangers will be 4421.10.0000, HTSUS, which provides for “Other articles of wood: Clothes hangers.” The column one, general rate of duty will be 3.2 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. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition to subheading 4421.10.0000, HTSUS, listed above. The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading. 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