The tariff classification of a seat component from Vietnam

N361875June 1, 2026CLA-2-94:OT:RR:NC:N5:433 CATEGORY: Classification TARIFF NO.: 9401.99.9085 Grace BentzLifetime Products Inc.PO Box 160010 Freeport Center Bldg., D-11Clearfield, UT 84016RE: The tariff classification of a seat component from VietnamDear Ms. Bentz:In your letter dated May 28, 2026 , you requested a tariff classification ruling. In lieu of samples, technicaland illustrative literature, a product description, and a manufacturing synopsis were provided for review.The “Pontoon Chair Frame” is a seating component constructed of linear, non-linear, concave, and convexaluminum metal frame rails. Information provided states, “[T]his is an aluminum chair frame to be designed,manufactured, and produced solely for the use in Lifetime pontoon boats. It cannot be used with any othercompetitors watercraft.” The chair frame dimensions approximate 18" in length, 24.3" in width, and 12.4" inheight. The seat frame legs and the base are welded, powder coated and will have four (4) pilot holes forincorporation of a seat foundation and assembly hardware (not included).The applicable subheading for the subject merchandise will be 9401.99.9085, Harmonized Tariff Schedule ofthe United States (HTSUS), which provides for “Seats (other than those of heading 9402), whether or notconvertible into beds, and parts thereof: Parts: Other: 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 convenienceand are subject to change. The text of the most recent HTSUS and the accompanying duty rates are providedat https://hts.usitc.gov/.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to theclassification stated above, the merchandise covered by this ruling may also need to be reported with eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated CargoSystems 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 asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Dharmendra Lilia at dharmendra.lilia@cbp.dhs.gov. Sincerely, (for)James P. ForkanDirectorNational Commodity Specialist Division