RE: The tariff classification of a fabric spa cover with a foam core from Canada

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 N365700 October 15, 2026 CLA-2-90:OT:RR:NC:N3:143 CATEGORY: Classification TARIFF NO.: 9019.10.2090 Wendy Camp CB Customs Brokerage Services Inc. 4450 Witmer Estates Suite 3 Niagara Falls, NY 14075 RE: The tariff classification of a fabric spa cover with a foam core from Canada Dear Ms. Camp: In your letter dated October 2, 2026, you requested a tariff classification ruling, on behalf of your client, PSP Fabricating Inc. The product under consideration is a fabric spa cover with a foam core, designed as a fitted, removable cover for a specific domestic spa or hot tub model. It consists of two rigids, tapered expanded-polystyrene (EPS) foam core panels reinforced internally with galvanized steel C-channels and vacuum-sealed in polyethylene film. The panels are enclosed in a computer-cut and sewn fabric jacket featuring a UV-, mildew-, and rot-resistant DuraTex® 900 solution-dyed polyester top fabric coated with water-repellent polyurethane, along with PVC-coated woven polyester bottom panels. A fabric hinge connects the panels, allowing the cover to fold in half for removal. The cover is intended to remain in place whenever the spa is unoccupied, including during heating, filtering, and circulating operations. It retains heat, reduces standby energy loss, protects the water from debris and weather, and restricts access to the spa. The jacket includes a zipper that allows the user to replace the jacket or foam core separately, reinforced lifting handles, a skirt, and adjustable locking straps with plastic side-release buckles. The product is sold through spa manufacturers, shipped fully assembled, and requires only placement on the spa and fastening of the locking straps. In your submission, you suggest classification for the fabric spa cover with a foam core under subheading 9019.10. 2090, Harmonized Tariff Schedule of the United States (HTSUS). We agree. The applicable subheading for the fabric spa cover with a foam core will be 9019.10. 2090, HTSUS, which provides for “Mechano-therapy appliances; massage apparatus; psychological aptitude-testing apparatus; ozone therapy, oxygen therapy, aerosol therapy, artificial respiration or other therapeutic respiration apparatus; parts and accessories thereof; Mechano-therapy appliances and massage apparatus; parts and accessories thereof; Parts and accessories.” The general duty rate 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 Dionisia Melman at dionisia.y.melman@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division