The tariff classification of metal furniture from Germany

N360145 April 9, 2026 CLA-2-94:OT:RR:NC:N5:433 CATEGORY: Classification TARIFF NO.: 9403.20.0090; 9403.99.9045 Michelle Baughman Transatlantic North America 2445 E Higgins, Suite B Elk Grove Village, IL 60007 RE: The tariff classification of metal furniture from Germany Dear Ms. Baughman: In your letter dated March 27, 2026, you requested a tariff classification ruling. In lieu of samples, illustrative literature and a product description were provided. The “3D Welding Table PROFI Premium Line (PP) D28,” is an industrial steel metal worktable designed for welding. The worktable allows the user with clamping options, 3-hole drilling patterns, system bores with protective countersink, and other functionality. The worktable is designed to provide a precise flat reference surface to establish baselines, locate features, and set out geometry for fabricated components prior to and during manufacturing operations. The worktable provides the user with heavy-duty industrial-grade weldments. The combined utilization of the worktable with the compatible tooling components enables the accurate location and alignment of workpieces. The worktable dimensions are 13' in length, 6.5' in width, 8'' in height, and weights 3,924 lbs. The worktable is heat-treated to create a hardened surface for usage in industrial environments. At the time of U.S. importation, the worktable will be imported as a complete unit (1 tabletop, 4 leg posts). Alternatively, the tabletop and the leg posts may be imported separately as individual component parts. The ruling request seeks classification of the subject merchandise in subheading 9017.10.80, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. This particular table is not a drafting table. Instead, it is a table with different holes in it that can be used for any host of different reasons. The user would not be drafting on this table but adding machines or other equipment to it. The holes will allow for any number of different machines to be clamped down securely but ultimately is not meant for one specific purpose. Classification in heading 9017 Harmonized Tariff Schedule (HTS) is excluded. The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitutes the official interpretation of the Harmonized System at the international level. The ENs to Chapter 94 of the Harmonized Tariff Schedule, for “Furniture,” states: “the term ‘furniture’ means: (A) Any ‘moveable’ articles (not included under other more specific headings of the Nomenclature), which have the essential characteristic that they are constructed for placing on the floor or ground, and which are used, mainly with a utilitarian purpose, to equip private dwellings, hotels, theatres, cinemas, offices, churches, schools, cafes, restaurants, laboratories, hospitals dentists’ surgeries, etc., or ships, aircraft, railway coaches, motor vehicles, caravan-trailers or similar means of transport. (It should be noted that, for the purposes of this Chapter, articles are considered to be ‘movable’ furniture even if they are designed for bolting, etc., to the floor, e.g., chairs for use on ships). Similar articles (seats, chairs, etc.,) for use in gardens, squares, promenades, etc., are also included in this category.” Further, the ENs to Chapter 94, heading 9403 of the HTS, provides “This heading covers furniture and parts thereof, not covered by the previous headings. It includes furniture for general use (e.g., cupboards, show cases, tables, telephone stands, writing desks, escritoires, book cases, and other shelved furniture (including single shelves presented with supports for fixing them to the wall), etc.), and also furniture for special uses.” Heading 9403 item (5) includes furniture for “Shops, stores, workshops, etc., such as: counters; dress racks; shelving units; compartment or drawer cupboards; cupboards for tools, etc.; special furniture (with cases or drawers) for printingworks.” The “3D Welding Table PROFI Premium Line (PP) D28,” is within the construct of Chapter 94, heading 9403, and item (5); the worktable is floor or ground standing moveable metal furniture. When imported complete (1 tabletop and 4 legs), the applicable subheading for the subject merchandise will be 9403.20.0090, HTSUS, which provides for “Other furniture and parts thereof: Other metal furniture: Other: Other.” The general rate of duty will be free. When imported separately (1 tabletop or 1 or more legs), the applicable subheading for the subject merchandise will be 9403.99.9045, HTSUS, which provides for “Other furniture and parts thereof: Parts: Other: Other: Other: Other: Of metal: 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 the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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 P. Forkan Director National Commodity Specialist Division