The tariff classification of a bottle pouch, a bottle bumper, and a straw topper from Cambodia

N351592 August 6, 2025 CLA-2-42:OT:RR:NC:N4:441 CATEGORY: Classification TARIFF NO.: 3926.40.0090; 3926.90.9989; 4202.92.9700; 9903.01.25 Maribeth Dedmon Dollar General Corporation 100 Mission Ridge Goodlettsville, TN 37072 RE: The tariff classification of a bottle pouch, a bottle bumper, and a straw topper from Cambodia Dear Ms. Dedmon: In your letter dated July 22, 2025, you requested a tariff classification ruling. You have submitted samples for our review. The submitted sample, which you referred to as the “Hydration Accessories Set,” is comprised of a bottle pouch, a silicone bumper, and a PVC straw topper. The three articles are not considered a set for tariff purposes since each article performs a different function in relation to the bottle; they do not function together towards the same activity. As such, they will be classified separately under their appropriate subheadings. The pouch is constructed with an outer surface of plastic sheeting. It has a zipper closure and two straps that allow it to be wrapped around a water bottle. In your request, you indicated that you believe that the straw topper would be classified under subheading 3923.50.0000, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. After the issuance of Jing Mei Automotive (USA) v. United States, 682 F. Supp. 3d 1354 (Ct. Int’l Trade 2023), “stoppers, lids, caps and other closures” of subheading 3923.50.0000, HTSUS, must be closures for use with some type of container or similar article used for packing, supporting, or conveyance of goods only. This straw topper is used with a drinking mug/tumbler. Therefore, classification in subheading 3923.50.0000, HTSUS, is precluded. Additionally, you proposed that the silicone plastic bumper would be correctly classified under subheading 3924.10.4000, HTSUS, as it would be similar to a coaster. We disagree as the plastic coasters classified in heading 3924 are specifically designed to protect tables from scratches, food spills, or stains. In contrast, this plastic silicone bumper is used to protect the bottle from scratches and dings. We note that heading 3924 does not have a parts nor accessories provision that could provide for this bumper or straw topper. Therefore, the bumper and straw topper are precluded from classification within heading 3924. Due to the decorative nature of the straw topper, we hold the opinion that the applicable subheading for it will be 3926.40.0090, HTSUS, which provides for “Other articles of plastics and articles of other materials of headings 3901 to 3914: Statuettes and other ornamental articles: Other.” The general rate of duty is 5.3 percent ad valorem. As the silicone bumper would be considered an article of plastic, and as it is not more specifically provided for elsewhere, the applicable subheading will be 3926.90.9989, HTSUS, which provides for “Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Other: Other.” The general rate of duty is 5.3 percent ad valorem. You suggested the bottle pouch is classified within subheading 4202.92.4500, HTSUS. While we agree that the pouch is an article of Heading 4202, the appropriate subheading for bottle pouch will be 4202.92.9700, HTSUS, which provides for other containers and cases, with outer surface of plastic sheeting material, other, other, other, other. The general rate of duty will be 17.6 percent ad valorem. 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. At this time products from all countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e., 9903.01.25, in addition to subheadings 3926.40.0090, 3926.90.9989, and 4202.92.9700, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling’s issuance. 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/. 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 and Border Protection 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, please contact National Import Specialist Vikki Lazaro at vikki.lazaro@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division