RE: The tariff classification of an erosion control blanket 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 N365836 October 16, 2026 CLA-2-46:OT:RR:NC:N5:130 CATEGORY: Classification TARIFF NO.: 4602.19.8000 Ms. Nicole Collier GHY International 572 South 5th Street Pembina, ND 58271 RE: The tariff classification of an erosion control blanket from Canada Dear Ms. Collier: In your letter, dated October 7, 2026, you requested a binding classification ruling on behalf of your client, ECB Verdyol. Information and a sample were submitted for our review. The product under consideration is a finished, three-layer erosion control blanket imported under style numbers S32-8 and S32-16. The blanket is rectangular and measures 244cm x 3430cm and 488cm x 3430cm, respectively. The blanket is constructed of a core of unwoven natural wheat and straw and is faced and backed with a photodegradable polypropylene knit net. The blanket is stitched at regular intervals with UV-degradable polyester thread. The blanket is machine-compressed before and after stitching. The blanket consists of 92.5 percent wheat and 7 percent net. It is manufactured without woven selvages, metal wire, or additional edge materials, and is unimpregnated, uncoated, unlaminated, and contains no cellular or compact coatings, transparent coverings, flocking, pattern coatings or other surface applications. In your letter, you suggest that the blanket is classifiable in subheading 6005.36.0020, Harmonized Tariff Schedule of the United States (HTSUS), which provides for warp knit fabrics of synthetic fibers. We disagree. The short-term erosion-control blanket is a composite good comprising a polypropylene knit net fabric (classifiable under Heading 6005) and a wheat-straw matrix (classifiable under Heading 4602). Classification of merchandise under the HTSUS is accomplished in accordance with the General Rules of Interpretation (GRIs). Because the erosion-control blanket is made predominantly of two materials classifiable in different headings, it is a composite good classified in accordance with GRI 3(b), which states, in part, that composite goods are to be classified as if they consisted of the component which gives them their essential character. In this case, the wheat-straw matrix imparts the essential character of the blanket, accounting for 92.5 percent of its weight and performing the primary protective function against erosion (absorbing impact, slowing runoff, and retaining moisture), while the remaining materials are intended to degrade in the sunlight. While the netting and thread merely hold the blanket together, the straw provides its bulk and main utility purpose. Therefore, classification under Heading 6005 is inappropriate, and the composite good is classified under Heading 4602 pursuant to GRI 3(b). Wheat and straw are plaiting materials as set forth in Note 1 to Chapter 46, HTSUS: In this chapter the expression "plaiting materials" means materials in a state or form suitable for plaiting, interlacing or similar processes; it includes straw, osier or willow, bamboos, rattans, rushes, reeds, strips of wood, strips of other vegetable material (for example, strips of bark, narrow leaves and raffia or other strips obtained from broad leaves), unspun natural textile fibers, monofilament and strip and the like of plastics and strips of paper, but not strips of leather or composition leather or of felt or nonwovens, human hair, horsehair, textile rovings or yarns, or monofilament and strip and the like of chapter 54. Because the wheat and straw are combined with netting and are machine-stitched, the erosion blanket is a finished article classifiable under heading 4602, HTSUS. Wheat and straw are vegetable materials. The applicable subheading for the erosion-control blankets will be 4602.19.8000, HTSUS, which provides for Basketwork, wickerwork and other articles, made directly to shape from plaiting materials or made up from articles of heading 4601; articles of loofah: Of vegetable materials: Other: Other: Other: Other. The general rate of duty is 2.3 percent ad valorem. 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 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 Laurel Duvall at laurel.duvall@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division