The tariff classification of portable, modular stage units from China

N352406 August 29, 2025 CLA-2-44:OT:RR:NC:N5:130 CATEGORY: Classification TARIFF NO.: 4421.99.9880; 9903.01.24; 9903.01.25; 9903.88.03 Mr. Calvin Oh JAS Forwarding USA Inc. 6165 Barfield Road Atlanta, GA 30328 RE: The tariff classification of portable, modular stage units from China Dear Mr. Oh: In your letter dated August 14, 2025, you requested a tariff classification ruling on behalf of your client, Moya Group, LLC. The ruling was for portable, modular stage units. Product information and photos were submitted for our review. The product under consideration is portable, modular stage units. The stage units each have a 4-foot by 4-foot platform that appears to be constructed of edge-glued lumber that has been framed with an aluminum edge. The platform is placed upon an expandable riser that is constructed of aluminum tubes with plastic cores. The riser has plastic feet on both top and bottom to stabilize the platform on the riser and unit on the ground. The riser expands outward to form a nearly 4-foot by 4-foot base that raises the platform approximately two feet. The units may be configured in any number or position to form a larger stage surface. The platforms support human weight and can be used for theater, performance, or event purposes. The modular stage units are constructed of multiple materials classifiable in different headings under the Harmonized Tariff Schedule of the United States (HTSUS) and therefore meet the definition of a composite good within the meaning of General Rule of Interpretation (GRI) 3(b). GRI 3(b) states, in pertinent part: (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 accordance with the Explanatory Notes (ENs) for GRI 3(b), the essential character of an item may 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 essential character of the modular stage units is imparted by the functional stage surface, i.e., the wood platform. The platforms could function as a stage surface even without the risers. Therefore, the stage units will be classified by the wooden platform with aluminum edging. The applicable subheading for the portable, modular stage units will be 4421.99.9880, HTSUS, which provides for Other articles of wood: Other: Other: Other: Other: Other. The rate of duty will be 3.3 percent ad valorem. 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 subheading 4421.99.9880, 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. At this time, products of China, Hong Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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 subheading 4421.99.9880, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 4421.99.9880, 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, i.e., 9903.88.03, in addition to subheading 4421.99.9880, 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, including information on exclusions and their effective dates, 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/programs-administration/trade-remedies, respectively. 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 Laurel Duvall at laurel.duvall@cbp.dhs.gov. Sincerely, (for) Denise Faingar Acting Director National Commodity Specialist Division