The tariff classification of a kitchen cabinet part from Italy.

N302486 February 13, 2019 CLA-2-94:OT:RR:NC:N4:433 CATEGORY: Classification TARIFF NO.: 9403.90.8041. John P. Engelhardt Rev-A-Shelf, LLC. 12400 Earl Jones Way Louisville, KY 40299 RE: The tariff classification of a kitchen cabinet part from Italy. Dear Mr. Engelhardt: In your letter dated January 2, 2019, you requested a tariff classification ruling. Illustrative literature and a product description were provided. Rev-A-Shelf, LLC. item 537115GRL-SG, the “Single Blind Corner Pullout Tray,” is a powder coated steel wire frame encasing a melamine particleboard base connected to a powder coated steel arm. All mounting hardware is included for installation as a pullout shelf into the base corner of a kitchen cabinet. The tray will be installed on standard ball bearing slides or a soft close slide mechanism. The tray can be configured with an additional tray to make a two-tier shelf. Based on the illustrative literature and product description provided, you are inclined to classify the “Single Blind Corner Pullout Tray” in subheading 9403.90.8041 of the Harmonized Tariff Schedule of the United States (HTSUS). The Explanatory Notes (ENs) to the HTSUS constitute the official interpretation of the tariff at the international level. EN VIII to General Rule of Interpretation (GRI) 3(b) provides: “the 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.” When the essential character of a composite good can be determined, the whole product is classified as if it consisted only of the material or component that imparts the essential character to the composite good. The “Single Blind Corner Pullout Tray” is composed of different components (steel and wood) and is considered a composite good for tariff purposes. The metal components provide structure, support, and movement of the item in and out of a cabinet. This office finds that the essential character of the “Single Blind Corner Pullout Tray” is imparted by the metal. The ENs to Chapter 94 of the HTSUS, “Parts,” state: “This Chapter only covers parts, whether or not in the rough, of goods of heading 9401 to 9403 and 9405, when identifiable by their shape or other specific features as parts designed solely or principally for an article of those headings. They are classified in this Chapter when not more specifically covered elsewhere.” This office is of the opinion that the “Single Blind Corner Pullout Tray” is a dedicated part to a kitchen cabinet, and is not more specifically provided for elsewhere in the tariff schedule. See Headquarters ruling H265042 dated July 18, 2016. The “Single Blind Corner Pullout Tray” is classified in heading 9403, HTSUS, specifically in subheading 9403.90.8041, which provides for “Other furniture and parts thereof: Parts: Other: Other: Other: Of metal: Other.” The rate of duty will be free. 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. This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Dharmendra Lilia at dharmendra.lilia@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division