RE: The tariff classification of metal furniture kits 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 N365466 October 20, 2026 CLA-2-94:OT:RR:NC:N5:433 CATEGORY: Classification TARIFF NO.: 9403.20.0086 Matt Jameson Thearent BV Toegangseweg 28 Boskoop, 2771 XM Netherlands RE: The tariff classification of metal furniture kits from China Dear Mr. Jameson: In your letter dated September 28, 2026, you requested a tariff classification ruling and stated that New York Ruling Letter (NYRL) N365452 covers the vertical, horizontal, base plate, and base plate pin metal components when imported separately, this submission is for the metal components when imported as kits (no textile drapes). In lieu of samples, technical and illustrative literature and product descriptions were provided for review. Item 1, the “Wentex FOH Kit & ATA Case (D7559)” consists of (1) 12 telescopic extruded aluminum vertical uprights, (2) 12 telescopic extruded aluminum horizontal drape supports, (3) 12 powder-coated steel base plates, (4) 12 powder-coated steel base plate pins, and (5) a travel storage case with fixed internal compartments and 4 swivel casters with brakes. The travel storage case is constructed of ABS plastic, plywood, and aluminum edge profiles. The dimensions of the travel case are 30" in length, 47" in width, and 29" in height. Item 2, the “Wentex LX Pipe & Drape Hardware Kit with Transport Trolly (89623)” consists of (1) 10 telescopic extruded aluminum vertical uprights, (2) 10 telescopic extruded aluminum horizontal drape supports, (3) 10 powder-coated steel base plates, (4) 10 powder-coated steel base plate pins, and (5) 1 powder-coated steel frame travel storage trolly. The trolly has 2 fixed casters, 2 swivel casters with brakes, and the dimensions are 31.5" in length, 29.5" in width, and 78" in height. Further, information provided states, when assembled, item 1 and item 2 “… forms up to 90 linear feet of free-standing structure (used with separately supplied drapes) for backdrops, room dividers, and masking.” After assembly, the floor standing displays will be used at trade shows, conventions, corporate events, theatres, hotels and other venues. The ruling request seeks classification of the subject merchandise in subheading 9403.20.0090 of the Harmonized Tariff Schedule of the United States, (HTSUS). We disagree. The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitutes the official interpretation of the Harmonized System at the international level. EN (I) to General Rule of Interpretation (GRI) 5(a) provides “This Rule shall be taken to cover only those containers which: 1. are specially shaped or fitted to contain a specific article or set of articles, i.e., they are designed specifically to accommodate the article for which they are intended. Some containers are shaped in the form of the article they contain; 2. are suitable for long term use, i.e., they are designed to have a durability comparable to that of the articles for which they are intended. These containers also serve to protect the article when not in use (during transport or storage, for example). These criteria enable them to be distinguished from simple packings; 3. are presented with the articles for which they are intended, whether or not the articles are packed separately for convenience of transport. Presented separately the containers are classified in their appropriate headings; 4. are of a kind normally sold with such articles; and 5. do not give the whole its essential character.” For item 1, the travel storage case is (1) specifically fitted to contain 12 telescopic extruded aluminum vertical uprights, 12 telescopic extruded aluminum horizontal drape supports, 12 powder-coated steel base plates, and 12 powder-coated steel base plate pins, (2) is suitable and designed for durability during storage and transport of the metal frame kit, (3) is presented with the articles for which it is intended, (4) is sold as a complete retail unit, and (5) does not provide the whole its essential character. In view of these facts, for item 1, the case and the metal frame kit will be classified together. For item 2, the travel storage trolly is (1) specifically fitted to contain 10 telescopic extruded aluminum vertical uprights, 10 telescopic extruded aluminum horizontal drape supports, 10 powder-coated steel base plates, and 10 powder-coated steel base plate pins, (2) is suitable and designed for durability during storage and transport of the metal frame kit, (3) is presented with the articles for which it is intended (4) is sold as a complete retail unit, and (5) does not provide the whole its essential character. In view of these facts, for item 2, the trolly and the metal frame kit will be classified together. The applicable subheading for item 1, the “Wentex FOH Kit & ATA Case” and item 2, the “Wentex LX Pipe & Drape Hardware Kit with Transport Trolly” 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