The classification of portable storage units from China

N360282 April 22, 2026 CLA-2-94:OT:RR:NC:N5:130 CATEGORY: Classification TARIFF NO.: 9406.90.0130 Mr. Ken Huang Janel Group, LLC 1025 W 190th St #390 Gardena, CA 90248 RE: The classification of portable storage units from China Dear Mr. Huang: In your letter, dated April 1, 2026, you requested a binding classification ruling on behalf of your client, Container Canopies, Inc. The ruling request was for portable steel storage units. Product information was provided for our review. The product under consideration is a steel portable storage unit measuring approximately 19 ft (L) x 8 ft (W) x 7.5 ft (H). The unit may have one set of doors at the end or two sets of doors on the side. You indicate that the unit is used for outdoor and construction site storage. It may also be used to transport household goods. The unit is portable, as evidenced by forklift slots and rings and hooks for hoisting. There is no indication that the unit is fitted specifically for carriage on a specific mode of transport, but merely designed to be strapped to a flatbed truck. The walls are 0.8mm-thick galvanized steel, about half the thickness of a standard shipping container. The units appear to be shipped flat and assembled after import into the United States. Note 4 to Chapter 94, Harmonized Tariff Schedule of the United States (HTSUS), defines prefabricated buildings: For the purposes of heading 9406, the expression "prefabricated buildings" means buildings which are finished in the factory or put up as elements, entered together, to be assembled on site, such as housing or worksite accommodation, offices, schools, shops, sheds, garages or similar buildings. The units are essentially sheds used for storage. They meet the terms of “prefabricated buildings”. The applicable subheading for the storage units will be 9406.90.0130, HTSUS, which provides for Prefabricated buildings: Other: Of metal: Other. The general rate of duty will be 2.9 percent ad valorem. 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 Laurel Duvall at laurel.duvall@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division