The tariff classification of a wall-mounted towel holder from China

N320091 June 24, 2021 CLA-2-44:OT:RR:NC:N4:434 CATEGORY: Classification TARIFF NO.: 4420.90.8000; 9903.88.03 John Strough Mohawk Global Logistics Corp. 123 Air Cargo Rd. North Syracuse, NY 13212 RE: The tariff classification of a wall-mounted towel holder from China Dear Mr. Strough: In your letter, dated June 18, 2021, you requested a tariff classification ruling on behalf of your client, Chefs Medal LLC. Photos and product specifications were provided for our review. The “Jumbo Clothespin Bathroom Towel Holder” is made to resemble a large spring clothespin made of wood. It measures approximately 12” high and 2.5” wide and is intended to mount on a wall. Per your submission, the holder can be used in the bathroom, kitchen or other rooms and can hold a variety of articles, including a towel, robe or kids’ art. You propose classification in subheading 4421.99.9780, Harmonized Tariff Schedule of the United States (HTSUS), as “other” articles of wood. We disagree. The holder is used as home furnishing, and as such, is more specifically provided for in heading 4420, HTSUS. The applicable subheading for the “Jumbo Bathroom Towel Holder” will be 4420.90.8000, HTSUS, which provides for…Other; wooden articles of furniture not falling within chapter 94. The rate of duty will be 3.2% 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 on the World Wide Web at https://hts.usitc.gov/current. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 4420.90.8000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty.  At the time of importation, you must report the Chapter 99 subheading 9903.88.03, HTSUS, in addition to subheading 4420.90.8000, 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, 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/remedies/301-certain-products-china, respectively. 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 Charlene Miller at charlene.s.miller@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division