The tariff classification of vehicle floor mats from China

 N307817 December 6, 2019 CLA-2-87:OT:RR:NC:N2:206 CATEGORY: Classification TARIFF NO.: 8708.99.8180; 9903.88.03 Elizabeth McGuffin Customs Manager Dollar General 100 Mission Ridge Goodlettsville, TN 37072 RE: The tariff classification of vehicle floor mats from China Dear Ms. McGuffin, In your letter dated November 20, 2019, you requested a tariff classification ruling. The item under consideration has been identified as a 4 Count Vehicle Floor Mat Set (SKU # 24227501). You state in your request that the 4 Count Vehicle Floor Mat Set sells as one unit containing four (4) mats; two (2) for the rear floor board and two (2) for the front floor board of a vehicle. The mats are constructed of PVC vinyl. Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is made in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative Section or Chapter Notes. You suggested a possible classification under heading 3918, Harmonized Tariff Schedule of the United States (HTSUS).  However, heading 3918 provides for floor coverings of plastics, whether or not self-adhesive, in rolls or in the form of tiles.  To be classified in 3918, the product must be in rolls or in the form of tiles.  These vinyl floor mats are not in rolls or in the form of tiles, but are rather vinyl mats designed to fit on the floors of automobiles.  For this reason, classification in 3918 would be precluded.  The applicable subheading of the 4 Count Vehicle Floor Mat Set (SKU # 24227501) will be 8708.99.8180, HTSUS, which provides for “Parts and accessories of the motor vehicles of heading 8701 to 8705: Other parts and accessories: Other: Other: Other: Other: Other.” The general rate of duty will be 2.5%. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8708.99.8180, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty.  At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8708.99.8180, HTSUS, listed above.   The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading.  For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china respectively. 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 http://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, please contact National Import Specialist Liana Alvarez at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division