RE: The tariff classification of desk and organizer mats from Portugal

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 N365337 October 5, 2026 CLA-2-63:OT:RR:NC:N3:351 CATEGORY: Classification TARIFF NO.: 4205.00.8000; 6307.90.9891 Mr. Rocco Kruse Rocco Kruse GmbH Anzengruberstrasse 23, Berlin 12043 Germany RE: The tariff classification of desk and organizer mats from Portugal Dear Mr. Kruse: In your letter dated September 23, 2026, you requested a tariff classification ruling. In lieu of samples, photographs of the desk and organizer mats were provided with your request. Item #1, described as “Madison,” is a desk mat intended to protect an individual’s desk and designed to provide a surface for a keyboard, mouse, and laptop. The mat consists of two layers: a 3-millimeter (mm) 100 percent wool nonwoven felt-face fabric and a 1-mm nonslip cellular rubber base. The two layers are joined by an acrylic adhesive. The rectangular shaped mat with rounded corners measures 31 ½ inches in length by 15 ¾ inches in width. The right-hand side of the mat features a 2mm thick tanned leather panel measuring 10 ¼ inches in length by 15 ¾ inches in width. The leather panel is sewn along three sides, creating an open pocket sleeve (open on the long edge side) that functions as an integrated mouse pad and paper storage pocket. You state the last four characters of the SKU# will be delineated by the color of the felt and leather: PA-MS-DES-OS-LGBL (Light Gray felt, Blue leather); PA-MS-DES-OS-LGDG (Light Grey felt, Dark Gray leather); and PA-MS-DES-OS-DGDG (Dark Grey felt, Dark Grey leather). Item #2, SKU# PA-RO-DES-OS-DG, described as “Rochelle,” is a desk mat intended to protect an individual’s desk and designed to provide a surface for a keyboard, mouse, and laptop. The mat consists of two layers: a 2-millimeter (mm) tanned dark grey leather top panel and a 1-mm nonslip cellular rubber base. The two layers are joined by acrylic adhesive and sewn on all four sides. The rectangular shaped mat with rounded corners measures 31 ½ inches in length by 15 ¾ inches in width. Item #3, described as “Chester,” is an organizer mat intended to protect an individual’s desk and designed to provide a surface for placing a smartphone, glasses, pens, and other everyday items. The mat consists of two layers: a 3-millimeter (mm) 100 percent wool nonwoven felt-face fabric and a 1-mm nonslip cellular rubber base. The two layers are joined by an acrylic adhesive. The rectangular shaped mat with rounded corners measures 10 ¼ inches in length by 4 ¼ inches in width. The left-hand side of the mat features a 2mm-thick tanned leather panel measuring 2 ¾ inches in length by 4 ¼ inches in width. The leather panel is sewn along three sides, creating an open pocket sleeve (open on the long edge side) with a cutout notch for easy access to hold cards and money. You state the last four characters of the SKU# will be delineated by the color of the felt and leather: PA-CH-iPH-OZ-LGBL (Light Grey felt, Blue leather); PA-CH-iPH-OZ-DGDG (Dark Grey felt, Dark Grey leather); PA-CH-iPH-OZ-LBBL (Light Blue felt, Blue leather); PA-CH-iPH-OZ-LGBR (Light Grey felt, Brown leather); and PA-CH-iPH-OZ-LBBR (Light Blue felt/Brown leather). General Rule of Interpretation (GRI) 1, Harmonized Tariff Schedule of the United States (HTSUS), states in part that for legal purposes, classification shall be determined according to the terms of the headings, any relative section or chapter notes and, unless otherwise required, according to the remaining GRI’s taken in order. Goods that are, prima facie, classifiable under two or more headings, are classifiable in accordance with GRI 3. GRI 3(a) states that the heading which provides the most specific description shall be preferred to headings providing a more general description. However, when two or more headings refer to part only of the items in a composite good, those headings are to be regarded as equally specific in relation to the goods, even if one of them gives a more complete or precise description of the good. As such, they are regarded as equally specific and classification of the composite good is to be determined by GRI 3(b) or GRI 3(c). GRI 3(b) states in part that composite goods, which cannot be classified by reference to GRI 3(a), are to be classified as if they consisted of the component which gives them their essential character. 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 the competing headings which equally merit consideration. The “Madison” and “Chester” mats are a composite good both made from a made up textile fabric (Heading 6307), a rubber base (Chapter 40), and a leather pocket panel (Chapter 42). We find that the essential character of the overall products cannot clearly be ascribed to either single material. Therefore, pursuant to GRI 3 (c), HTSUS, the “Madison” and “Chester” mats will be classifiable under heading 6307, HTSUS, which occurs last in numerical order among those which equally merit consideration. The “Rochelle” desk mat is a composite good made from both a rubber base (Chapter 40) and a leather top (Heading 4205). We have determined that the essential character of the product is imparted by the leather component, given its primary visual impact and predominance in weight. Therefore, pursuant to GRI 3(b), the “Rochelle” desk mat will be classifiable under heading 4205, HTSUS. The applicable subheading for the “Madison” and “Chester” mats will be 6307.90.9891, HTSUS, which provides for ““Other made up articles, including dress patterns: Other: Other: Other: Other: Other.” The rate of duty will be 7 percent ad valorem. The applicable subheading for the “Rochelle” mat will be 4205.00.8000, HTSUS, which provides for “Other articles of leather or of composition leather: Other: Other: Other.” The 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 Kristine Dodge at kristine.dodge@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division