The tariff classification of a picnic table and bench seating from Poland

N358240 February 17, 2026 CLA-2-94:OT:RR:NC:N5:433 CATEGORY: Classification TARIFF NO.: 9403.20.0090 Javier Fuente ML Sourcing 10805 SW 75th St Miami, FL 33173 RE: The tariff classification of a picnic table and bench seating from Poland Dear Mr. Fuente: In your letter dated January 27, 2026, you requested a binding tariff classification ruling. In lieu of samples, illustrative literature and a product description were provided. Model 13.440, the “Domino Picnic Table,” is a metal frame circular table that is permanently affixed and integrated with 3 metal frame bench seats. The tabletop surface, table legs, bench seat foundations, and the bench seat legs are adapted one-to-the-other and form a unitary whole. The picnic table is designed for permanent installation in public and private outdoor environments such as parks, streetscapes, plazas, campuses, and commercial developments. The picnic table frame and the bench seating frame will be constructed of carbon steel or stainless steel. The tabletop surface and the bench seat foundation surface will be constructed of wood (hardwood or softwood) or high-pressure laminate (HPL) planks with rectangular cross-sections. The overall dimensions are approximately 18" for the seat height, 18" for the seat depth, 30" for the table height, and 65" in diameter for the tabletop surface. The bench seats can accommodate up to nine individuals. The flat and level picnic tabletop surface will allow for the placement of objects, and the picnic table has a central opening in the middle for the placement of an umbrella (not included). The picnic table and the bench seats can either stand alone or be securely anchored to the ground with expansion bolts. The picnic table and bench seating will be imported fully manufactured and assembled with no further processing or transformation occurring after U.S. importation. The ruling request seeks classification of the subject merchandise in Chapter 94 (Furniture) of the Harmonized Tariff Schedule (HTS) as opposed to Chapter 73 (Articles of Iron or Steel) HTS. We agree. The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitutes the official interpretation of the Harmonized System at the international level. EN IX to General Rule of Interpretation (GRI) 3(b) provides: “for the purposes of this Rule, composite goods made up of different components shall be taken to mean not only those in which the components are attached to each other to form a practically inseparable whole but also those with separable components, provided these components are adapted one to the other and are mutually complementary and that together they form a whole which would not normally be offered for sale in separate parts.” The “Domino Picnic Table” is a composite good comprised of different materials (20% wood, 80% metal) and different components (metal frame bench seats / Heading 9401, metal picnic table / Heading 9403). The wood and metal bench seats and the wood and metal picnic table are adapted one to the other, are mutually complementary, and together they form a unitary whole. The metal frame of the picnic table and the metal frame of the bench seats provide structural integrity, secure mounting, fitting, and positioning of the flat wooden salted bench seat surface and the flat wooden slated tabletop surface. Further, the weight distribution of the complete picnic table is 80% metal and 20% wood. The essential character of the “Domino Picnic Table,” as a whole, is imparted by the metal table. The applicable subheading for the subject merchandise will be 9403.20.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other furniture and parts thereof: Other metal furniture: Other: Other.” The general rate of duty will be free. The 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on the Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ. 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 Dharmendra Lilia at dharmendra.lilia@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division