RE: The tariff classification of modular partition panels from China

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364817 September 30, 2026 CLA-2-94:OT:RR:NC:N5:433 CATEGORY: Classification TARIFF NO.: 9403.20.0086; 9403.89.6020 Theo Milcent Wall Up 19 Rue Saint Pierre Neuilly-Sur-Seine, 92200 France RE: The tariff classification of modular partition panels from China Dear Mr. Milcent In your letter dated September 3, 2026, you requested a tariff classification ruling. In lieu of samples, technical and illustrative literature, product descriptions, and a manufacturing synopsis were provided for review. Item 1, the “Standard Wall (100x200),” item 2, the “Standard Wall (50x200),” item 3, the “Wall Miroir (100x200),” and item 4, the “Wall Magnétique (100x200)” are complete, unassembled, and modular floor-standing rigid panels that will be used by event-equipment rental companies as partitions, screens, backdrops, display surfaces, and room dividers for photo and film studios, event venues, showrooms, fashion shows, trade shows, and pop-up stores. The partitions are designed to be free-standing; they are not anchored to the floor, wall, or ceiling of a building, and they are assembled, dismantled, configured, and reconfigured without the use of tools. The partitions are constructed of 100% polyester textile covers, expanded polypropylene (EPP) foam boards, and hook-and-loop strips that are permanently mounted onto 1.2 mm square hollow aluminum vertical frame rails and horizontal reinforcing bars. The panels are designed to stand vertically on the floor and be joined one to the other, side-by-side, or at an angle using separate connector pieces (folded steel “I, L, T, and X”) connectors (sold separately). The partition panel surface of item 1 and 2 will be made available in different colors; the partition panel surface of item 3 will be a non-beveled 3 mm thick glass mirror; the partition panel surface of item 4 will be a 0.5 mm thick ferromagnetic steel sheet. 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 (HTS), 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.” In view of the facts provided, the fabric partition panels, the mirror partition panel, and the magnetic partition panel are within the construct of the Chapter 94 ENs for furniture. Furthermore, Chapter 94, Legal Note 2 and 2(a) provides: “articles (other than parts) referred to in headings 9401 to 9403 are to be classified in those headings only if they are designed for placing on the floor or ground. The following are, however, to be classified in the above-mentioned headings even if they are designed to be hung, to be fixed to the wall or to stand one on the other: 2(a) Cupboards, bookcases, other shelved furniture (including single shelves presented with supports for fixing them to the wall) and unit furniture.” The partition panels are designed to be placed on the floor or ground, are designed to be placed side-by-side other partition panels and are designed to be configured or reconfigured; the fabric partition panels, the mirror partition panel, and the magnetic partition panel falls within the construct of Chapter 94, Legal Note 2, and 2(a). Additionally, 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.” Items 1 and 2 are composite goods comprised of different materials (metal, plastic, textile) and different components (vertical and horizontal rails, foam board, multi-color polyester textile). Item 3 is a composite good comprised of different materials (metal, plastic, textile, glass) and different components (vertical and horizontal rails, foam board, glass mirror). Item 4 is a composite good comprised of different materials (metal, plastic, textile) and different components (vertical and horizontal rails, foam board, non-alloy ferromagnetic steel sheet). Items 1 through 4 are each constructed of materials that have been adapted one to the other, are mutually complementary, and each individual panel forms a unitary whole. For items 1 and 2, the multi-colored polyester textile panel creates the partition space and is the indispensable attribute that strongly marks or serves to distinguish the structure, core or condition of the panel. For item 3, the glass mirror creates the partition space and is the indispensable attribute that strongly marks or serves to distinguish the structure, core or condition of the panel. For item 4, the ferromagnetic steel sheet creates the partition space and is the indispensable attribute that strongly marks or serves to distinguish the structure, core or condition of the panel. The essential character of item 1 and 2, as a whole, is imparted by the polyester textile fabric material; the essential character of item 3, as a whole, is imparted by the glass mirror material; the essential character of item 4, as a whole, is imparted by the ferromagnetic steel material. The applicable subheading for items 1, 2, and 3 will be 9403.89.6020, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other furniture and parts thereof: Furniture of other materials, including cane, osier, bamboo or similar materials: Other: Other: Other.” The general rate of duty will be free. The applicable subheading for item 4 will be 9403.20.0086, HTSUS, which provides for “Other furniture and parts thereof: Other metal furniture: Other: Counters, lockers, racks, display cases, shelves, partitions and similar fixtures: 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