RE: Request for Internal Advice; Tariff Classification of a pet bowl

HQ H354882 August 6, 2026 OT:RR:CTF:CPMMA H354882 GH CATEGORY: Classification TARIFF NO: 7323.93.00 Center Director Agriculture and Prepared Products Center of Excellence and Expertise U.S. Customs and Border Protection th 6601 N.W. 25 St., Suite 261 Miami, Florida 33122 Attn: Dana L. Giammanco, Import Specialist RE: Request for Internal Advice; Tariff Classification of a pet bowl Dear Center Director: This letter is in reply to your request for internal advice, received on October 29, 2025, submitted by Roberts & Kehagiaras LLP, on behalf of Loving Pets Corporation (the requestor). The internal advice request concerns U.S. Customs and Border Protection’s (CBP) tariff classification of a pet bowl under the Harmonized Tariff Schedule of the United States (HTSUS). Our decision is set forth below. FACTS: At issue is the “Bella Bowl,” a pet bowl consisting of a stainless steel interior with a decorative, outer polyresin plastic exterior and a removable plastic ring on the bottom. The plastic exterior is non-removable from the stainless steel bowl. The outer plastic shell features paw prints and dog bones around the exterior of the bowl. The removable plastic ring at the bottom prevents the steel bowl from skidding, spilling, scratching, and making noise while the dog eats or drinks from it. The pet bowl is available in four different sizes. The small bowl measures approximately 5.5 inches by 1.75 inches and holds 15 ounces. The medium bowl measures approximately 6.75 inches by 2 inches and holds 27 ounces. The large bowl measures approximately 8.5 inches by 2.5 inches and holds 54 ounces. The extra-large bowl measures approximately 9 inches by 3 1 inches and holds 72 ounces. The merchandise is marketed and sold as a stainless steel bowl on the importer’s (Loving Pets) website: https://lovingpetsproducts.com/original-bella-bowls/ (last visited June 24, 2026). Internet research reveals that the merchandise is also marketed and sold on the Chewy website as a “stainless steel dog & cat bowl:” https://www.chewy.com/ loving- pets-bella-non-skid-stainless/dp/39580 (last visited June 24, 2026). ISSUE: Whether the instant merchandise is classified in heading 3924, HTSUS, which provides for “Tableware, kitchenware, other household articles and hygienic or toilet articles, of plastics,” or heading 7323, HTSUS, which provides for “Table, kitchen or other household articles and parts thereof, of iron or steel; iron or steel wool; pot scouring or polishing pads, gloves and the like, of iron or steel.” LAW AND ANALYSIS: Classification of goods under the HTSUS is governed by the General Rules of Interpretation (GRI). GRI 1 provides that classification shall be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of 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. The HTSUS provisions under consideration are as follows: 3924 Tableware, kitchenware, other household articles and hygienic or toilet articles, of plastics 7323 Table, kitchen or other household articles and parts thereof, of iron or steel; iron or steel wool; pot scouring or polishing pads, gloves and the like, of iron or steel The merchandise at hand consists of three different materials viz., a stainless steel interior with a decorative outer polyresin plastic exterior and a removable plastic ring on the bottom. GRI 2(b) provides in pertinent part that “[t]he classification of goods consisting of more than one material or substance shall be according to the principles of Rule 3.” Consequently, consideration is given to GRI 3, which provides, in relevant part, as follows: 3. When, by application of rule 2(b) or for any other reason, goods are, prima facie, classifiable under two or more headings, classification shall be effected as follows: (b) Mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale, which cannot be classified by reference to 3(a), shall be classified as if they consisted of the material or component which gives them their essential character, insofar as this criterion is applicable. In interpreting the HTSUS, the Harmonized Commodity Description and Coding System Explanatory Notes (“ENs”) may be utilized. The ENs, though neither dispositive nor legally binding, provide commentary on the scope of each heading of the HTSUS, and are the official interpretation of the Harmonized System at the international level. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989). 2 EN (VIII) to GRI 3(b), states, “[t]he factor which determines essential character will vary as between different kinds of goods. It may, for example, 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 goods.” The requestor asserts that the merchandise is classifiable in subheading 3924, HTSUS, which provides for “Tableware, kitchenware, other household articles and hygienic or toilet articles, of plastics.” Specifically, the requestor asserts that the pet bowl is an article of plastic which provides its essential character under GRI 3(b). Therefore, we first must determine the essential character of the pet bowl. In Estee Lauder, Inc. v. United States, 815 F. Supp. 2d 1287, 1299–1300 (Ct. Int’l. Trade 2012), the Court of International Trade (CIT) held that under GRI 3(b) composite goods should be classified according to the item that provided the essential character. Essential character is determined based on a review of “the nature of the [good], its bulk, quantity, weight or value, or by the role of a constituent [good] in relation to the use of the goods.” Id. at 1300. This list is not exhaustive. The essential character of an article is “that which is indispensable to the structure, core or condition of the article, i.e., what it is. Further, the existence of other materials which impart something to the article ought not to preclude an attempt to isolate the most outstanding and distinctive characteristic of the article.” Structural Indus. v. United States, 29 CIT 180, 185, 360 F. Supp. 2d 1330, 1336 (2005). We disagree with the requestor’s claim that the outer polyresin plastic exterior imparts the essential character of the pet bowl. CBP has consistently held under GRI 3(b) that stainless steel pet food bowls combined with plastic or rubber coatings, floor rings or various trays and stands are classified in heading 7323, HTSUS, because the stainless steel bowl imparts their essential character. See New York Ruling Letter (“NY”) N012093, dated June 8, 2007 (concerning a stainless steel pet bowl with a rubber ring around the base), NY M83441, dated May 26, 2006 (concerning two stainless steel pet bowls in a fitted plastic carry case), NY N259034, dated November 25, 2014 (concerning stainless steel pet bowls on a rubber tray), NY R04849, dated October 2, 2006 (concerning two stainless steel pet bowls in a decorative wooden stand), NY N031327, dated July 1, 2008 (concerning an adjustable iron stand and two stainless steel pet bowls), NY C85752, April 1, 1998 (concerning stainless steel pet bowls supported by a wrought iron frame), and NY N097895, dated April 9, 2010 (concerning stainless steel pet bowls fitted in a bamboo stand). Based on internet research set forth above, there are marketed differences between pet bowls that are stainless steel and pet bowls that are plastic. In this instance, the requestor specifically markets the merchandise as stainless steel to differentiate the bowl from other similar products consisting entirely of plastic. The pet bowl is listed on the requestor’s website as “stainless steel dog bowl.” (Last visited June 24, 2026.) Additionally, the pet bowl is also listed on the Chewy website as “stainless steel dog & cat bowl.” (Last visited June 24, 2026.) Furthermore, the online listings for the merchandise specifically highlight the bowl’s stainless steel component in the product description stating that the stainless steel is, “[h]ygienic: [r]ust resistant; offers a healthy alternative to plastic; doesn’t hold odors,” “[b]acteria resistant 3 1 2 stainless steel interior,” and “vet-recommended stainless steel interior.” As noted in the product description, unlike pet bowls composed entirely of plastic, the stainless steel pet bowls are durable, do not harbor bacteria, and are generally considered than healthier than plastic. The stainless steel is impermeable so it does not absorb germs or leach chemicals, it is machine washable, it is durable and break-proof (undamaged by drops or chewing by pets) and lasts without deterioration for many years. The function and qualities (hygienic, durability and safety) of the stainless steel material as the interior component of the Bella Bowl imparts its essential character as a stainless steel pet bowl. The requestor contends that the exterior polyresin plastic imparts the essential character of the merchandise, and therefore, the pet bowl should be classified in heading 3924, HTSUS. The requestor further contends that the outer plastic shell in each bowl ranges from 1.15 to 1.50 millimeters in thickness, whereas the inner steel lining in each bowl is only 0.29 mm thick. Thus, the requestor asserts that because the outer layer of plastic is about four times as thick as the steel inner lining, the plastic exterior provides insulation, structural support, protection, and noise reduction; whereas the inner stainless steel lining merely provides a sanitary function that is subordinate to the function of the plastic exterior. To support their argument, the requestor cites to NY N181424, dated September 20, 2011, NY N338560, dated March 20, 2024, and NY N125655, dated October 28, 2010. NY N181424, NY N338560, and NY N125655 which involve insulated food and beverage containers with lids. NY N181424, NY N338560, and NY N125655 are not applicable to the merchandise at hand because the plastic of the pet bowl at issue is not designed to provide insulation. As marketed, the purpose of the exterior polyresin plastic is purely decorative, and it 3 is not designed to provide an insulation function. Additionally, unlike NY N181424, NY N338560, and NY N125655, there is no lid component included with the merchandise which further evidences the lack of insulation function. Furthermore, while the exterior polyresin plastic is four times as thick as the interior lining, the bulk material of a composite good is not the only factor that is considered in an essential character analysis. Instead, here we must consider the role of a constituent polyresin plastic exterior in relation to the use of the good. As noted above, the plastic exterior provides aesthetic appeal that is subordinate to the essential function and character imparted by the stainless steel component. It is the stainless steel component that makes the bowl function as a vessel for the dog to eat or drink from and provides the bowl’s structure. Therefore, the essential character of the pet bowl is the stainless steel component as per GRI 3(b) analysis above. The pet bowl should be classified in subheading 7323.93.00, HTSUS, which provides for “Table, kitchen or other household articles and parts thereof, of iron or steel; iron or steel wool; pot scourers and scouring or polishing pads, gloves and the like, of iron or steel: Other: Of stainless steel.” 1 See Bella Bowl - Stainless Steel Dog Bowl - 9 Colors - 4 Sizes, LOVING PETS https://lovingpetsproducts.com/original-bella-bowls/ (last accessed Feb. 13, 2026). 2 See Loving Pets Bella Non-Skid Stainless Steel Dog & Cat Bow, CHEWY https://www.chewy.com/loving-pets-bella-non-skid-stainless/dp/39580 (last accessed Feb. 13, 2026). 3 As advertised online, the pet bowl contains a “Attractive poly-resin exterior” and “Stylish appearance: Our 9 colors make sure to reflect a sophisticated choice that works with any décor” and no reference is made to any insulation properties. See id. 4 HOLDING: By application of GRI 3(b), the instant pet food bowls are properly classified in subheading 7323.93.00, HTSUS, which provides for “Table, kitchen or other household articles and parts thereof, of iron or steel; iron or steel wool; pot scourers and scouring or polishing pads, gloves and the like, of iron or steel: Other: Of stainless steel.” The 2026 rate of duty is 2% 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 at https://hts.usitc.gov/current. You are to mail this decision to the internal advice requester no later than 60 days from the date of the decision. At that time, the Office of Trade, Regulations and Rulings will make the decision available to CBP personnel, and to the public on the Customs Rulings Online Search System (CROSS) at https://rulings.cbp.gov/ which can be found on the U.S. Customs and Border Protection website at http://www.cbp.gov and other methods of public distribution. Sincerely, Yuliya A. Gulis, Director Commercial and Trade Facilitation Division 5