The tariff classification of golf umbrellas from China

N347448 April 16, 2025 CLA-2-66:OT:RR:NC:4:434 CATEGORY: Classification TARIFF NO.: 6601.99.0000; 9903.01.24; 9903.01.63 Marilyn Santos Supreme International 3000 NW 107th Ave. Miami, FL 33172 RE: The tariff classification of golf umbrellas from China Dear Ms. Santos: In your letter, dated March 25, 2025, you requested a tariff classification ruling on one style of golf umbrella. A sample and additional descriptive information were provided for our review. Style OGAFF090 is a golf umbrella. The shaft and frame are constructed from fiberglass, while the canopy, which measures approximately 53 inches across when open, is made from 100% polyester pongee. It features a vented top section. The umbrella is collapsible (opens and closes), but the shaft is not telescoping; rather, the shaft is a fixed length. You propose classification of the umbrella in subheading 6601.91.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for umbrellas having a telescopic shaft. We disagree. Based on the sample, the shaft is not telescopic. The applicable subheading for the golf umbrella 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. 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 subheadings 6601.99.0000, HTSUS, listed above. Effective April 5, 2025, Executive Orders implemented ?Reciprocal Tariffs.? ?All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs.? Products of China, including Hong Kong and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. ??At the time of entry, you must report the Chapter 99 heading applicable to your product classification, 9903.01.63, in addition to subheading 6601.99.0000, 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 Notes cited above and the applicable Chapter 99 subheadings. You inquired whether the Section 232 additional duties on certain derivative aluminum products applies to the golf umbrellas. ?Articles of subheading 6601.99.0000, HTSUS, are not among those listed in Annex 1 to Presidential Proclamation 10895. 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 charlene.s.miller@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division