The tariff classification and marking of a Range Doctor kit from South Korea

N362197 July 6, 2026 CLA-2-34:OT:RR:NC:N3:136 CATEGORY: Classification; Marking TARIFF NO.: 3405.40.0000 Hyeyeon Lee Shinhan Customs Services Co., LTD 704, Nonhyeon-ro, Gangnam-gu Seoul 06052 Korea, South RE: The tariff classification and marking of a Range Doctor kit from South Korea Dear Mr. Lee: In your letter dated June 9, 2026, on behalf of your client, SH Dream Co., you requested a tariff classification and marking ruling on a Range Doctor kit. In your submission, the subject product is described as a two-component kit, model name Range Doctor, that functions to clean and maintain top surfaces of kitchen cooking appliances. The kit consists of a 200 ml container of liquid cream (scouring paste), which serves as a polishing and protective coating agent, and a dedicated scraper with three replacement blades. These two components are packaged together and suitable for retail sale in their imported condition. The liquid cream, retail packaging box, and label are made in South Korea, and the scraper is made in China. The finished product will be packaged in South Korea and shipped to the United States. You state that the liquid cream is formulated with a natural abrasive (diatomaceous), it gently and safely removes burnt-on food residues and stubborn grease stains without leaving scratches on the cooktop surface. The white mineral oil component restores the original luster of dulled cooktops, returning them to the transparent and clean appearance they had when first installed. The protective layer formed after stain removal prevents routine daily scratches and proactively protects the cooktop surface from future contamination. The dedicated scraper consists of a plastic body equipped with a manual sliding switch and three replacement stainless-steel blades. It features a safety structure where the blade is either exposed or retracted into the housing depending on the switch operation. While light stains can be easily removed with just a sponge or a scouring pad, burnt marks or thick grime that have been neglected for a long time and have completely adhered to the cooktop are difficult to eliminate using sponges or scouring pads alone. In such cases, this dedicated scraper is utilized to scrape off and remove the contaminants by applying physical force. Once the polishing coating agent is applied in the first step and allowed to rest, it softens the hardened stains. Subsequently, this scraper is pushed horizontally along the surface to scrape away and remove only the contaminants without causing any damage to the cooktop's inherent surface. The Explanatory Notes to the Harmonized Tariff System, although not legally binding, provide guidance in the interpretation of the Harmonized Commodity Description and Coding System at the international level. Explanatory Note X to GRI 3 (b) provides that the term "goods put up in sets for retail sale" means goods that; (a) consist of at least two different articles which are, prima facie, classifiable in different headings; (b) consist of articles put up together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without re-packing. Goods classifiable under GRI 3 (b) are classified as if they consisted of the material or component which gives them their essential character, which 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 article. GRI 3 (c) provides that when goods cannot be classified by reference to GRI 3 (a) or 3 (b), they are to be classified in the heading that occurs last in numerical order among those which equally merit consideration. The Range Doctor kit will be classified as a set for tariff classification purposes in accordance with GRI 3(b), with the essential character imparted by the scouring paste; we believe this component is indispensable to the product’s primary function and use. The applicable subheading for the Range Doctor kit will be 3405.40.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Polishes and creams, for footwear, furniture, floors, coachwork, glass or metal, scouring pastes and powders and similar preparations (whether or not in the form of paper, wadding, felt, nonwovens, cellular plastics or cellular rubber, impregnated, coated or covered with such preparations), excluding waxes of heading 3404: Scouring pastes and powders and other scouring preparations. The general rate of duty will be free. Marking Marking Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940). With respect to the subject product, we have determined that the packing process in South Korea, which is described above, does not result in a substantial transformation of the China origin scraper with three replacement blades. Therefore, in our opinion, the country of origin for the scraper with three replacement blades for marking purposes is China. The country of origin marking requirements of 19 U.S.C. § 1304 and 19 C.F.R. Part 134 will be satisfied with the use of the words “Made in China,” “Product of China,” or other words of similar meaning. The country of origin for the liquid cream (scouring paste) for marking purposes is South Korea. The country of origin marking requirements of 19 U.S.C. § 1304 and 19 C.F.R. Part 134 will be satisfied with the use of the words “Made in South Korea,” “Product of South Korea,” or other words of similar meaning. 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. This merchandise may be subject to the requirements of the Toxic Substances Control Act (TSCA), which are administered by the U.S. Environmental Protection Agency. Information on the TSCA can be obtained by contacting the EPA at 1200 Pennsylvania Avenue, N.W., Mail Code 70480, Washington, D.C., by telephone at (202) 554-1404, or by visiting their website at www.epa.gov 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 Nuccio Fera at nuccio.fera@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division