The tariff classification of an all-in-one pillow and blanket combination from China

N304210 May 29, 2019 CLA-2-63:OT:RR:NC:N3:349 CATEGORY: Classification TARIFF NO.: 6301.40.0020 Ms. Marianne Casserly SnugglyRoll Inc. 7315 Gordons Road Falls Church VA 22043 RE: The tariff classification of an all-in-one pillow and blanket combination from China Dear Ms. Casserly: In your letter dated May 3, 2019, you requested a tariff classification ruling. A sample accompanied your request. The sample will be retained for training purposes. The submitted sample, identified as a “SnugglyRoll,” is an all-in-one pillow and blanket combination made from 100 percent polyester knit microplush fabric. The blanket portion is 83 inches (width) X 70 inches (length). Sewn to the top edge of the blanket, approximately 7 inches from the top left corner, is a self-fabric pillow cover measuring 18 inches X 19 inches. The pillow cover has a zipper closure on one side. Inserted into the cover is a pillow insert which you state is also 100 percent polyester. You suggest the SnugglyRoll is intended to be used two ways. When unrolled with the face side down, the user rests his or her head on the pillow, lying on the portion of the blanket which exists below the pillow and using the remaining blanket as a cover to provide warmth. The SnugglyRoll can also be used as a bolster pillow in its rolled condition. To roll, the user folds the blanket in half, length wise, and then folds both outer edges inward to line up with the outer edges of the pillow. The item is then folded from the top, beginning with the pillow, to the bottom and is secured by hook and loop tabs. In the folded position, the decorative grosgrain ribbon trim and self-fabric carry handle which exist on the bottom side of the blanket in its unfolded condition are exposed. In your letter, you suggest classification is appropriate under 9404.90.2000, Harmonized Tariff Schedule of the United States (HTSUS), and cite two rulings, NY L83515 and NY B83490. The two items in these rulings are of differing construction, configuration, material and dimensions. As a result, classification for the item in NY L83515 was determined under General Rule of Interpretation (GRI) 3(c), while the classification for the item in NY B83490 was determined under GRI 3(b). The SnugglyRoll differs in construction, configuration, material and size from both of the articles in the cited rulings. As such, rulings NY L83515 and NY B83490 are not relevant to the classification of the SnugglyRoll under consideration. The SnugglyRoll is considered a composite article. It is our opinion that classification, in this case, can be determined under GRI 3(b) with the blanket providing the essential character. The applicable subheading for the SnugglyRoll will be 6301.40.0020, HTSUS, which provides for “Blankets and traveling rugs: Blankets (other than electric blankets) and traveling rugs, of synthetic fibers: Other.” The rate of duty will be 8.5 percent ad valorem. 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 on the World Wide Web at https://hts.usitc.gov/current. This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Kim Wachtel at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division