RE: The tariff classification of a seat from Vietnam

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 N365341 September 29, 2026 CLA-2-94:OT:RR:NC:N5:433 CATEGORY: Classification TARIFF NO.: 9401.80.6030 Rocco Kruse Rocco Kruse GmbH Anzengruberstrasse, 23 Berlin 12043 Germany RE: The tariff classification of a seat from Vietnam Dear Mr. Kruse: In your letter dated September 23, 2026, you requested a tariff classification ruling. In lieu of samples, technical and illustrative literature, a product description, and a manufacturing synopsis were provided for review. “EVENaBAG” is a combination travel bag with storage compartments and a portable seat that is constructed of Cordura textile, leather, a pair of fiberglass rods, and sewn-in foam padding. The bag has two large main compartments for storage and organization of various items, accommodates a laptop with a screen size of up to 16 inches, and is equipped with shoulder straps and a shoulder pad. The leather elements are located on the bag’s flap, base, and the storage compartment. The pair of fiberglass rods and the foam padding support the shape and stability of the backrest. The shoulder pad and straps allow the user to carry the bag over the shoulder, across the body, or as a backpack. A zipper pocket is located at the base which stows a mat that unfolds and extends for seating. The mat provides portable seating for outdoor recreation such as picnics, camping, hunting, fishing, beach, lakes, concerts, hiking, and sporting events. The dimensions approximate 14.96” in length, 14.7” in width, 5.11” in depth, weights 3.75 lbs. The Harmonized Commodity Description and Coding System Explanatory Notes (“ENs”) constitute the official interpretation of the Harmonized System at the international level. EN XII to General Rule of Interpretation (GRI) 3(c) provides in part: “when goods cannot be classified by reference to Rule 3(a) specific description or 3(b) essential character, they are to be classified in the heading which occurs last in numerical order among those which equally merit consideration in determining their classification.” EVENaBAG is a composite good comprised of a backpack (4202) and a seat (9401). The backpack and the seat are permanently affixed from one to the other and form a unitary whole. EVENaBAG is suitable for functional use both as a backpack and as a portable seat; neither use is casual, incidental or subordinate to the other. Collectively, no essential character can be determined because no one single component is more important than the next. EVENaBAG will be classified according to the component occurring last in numerical order within the appropriate tariff headings; in this case, seats of heading 9401 of the Harmonized Tariff Schedule (HTS), is last. The applicable subheading for the subject merchandise will be 9401.80.6030, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Other seats: 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 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