The tariff classification of pillow and pillowcase samples from China

N352129
August 22, 2025
CLA-2-94:OT:RR:NC:N2:349
CATEGORY: Classification
TARIFF NO.: 9811.00.60
Ms. Kendra Highlands QVC Group 1200 Wilson Drive West Chester, PA 19380 RE: The tariff classification of pillow and pillowcase samples from China Dear Ms. Highlands: In your letter dated August 7, 2025, you requested a binding ruling on whether certain furnishing articles may be treated as properly marked samples for the purpose of soliciting orders for foreign merchandise eligible under subheading 9811.00.60, Harmonized Tariff Schedule of the United States (HTSUS). In lieu of samples, photographs of clearly marked samples were provided. Item # 1, Style # S 96113, is described as a bed pillow with a 100 percent cotton woven fabric shell and filling of memory foam and polyester fiberfill. The pillow measures 26 x 18 x 5.5 inches. The face of the pillow is clearly marked with the word “SAMPLE,” approximately 8 × 15 inches, using a permanent marker with indelible ink. Item # 2, Style # S 90941, is described as a “pillowcase” of 100 percent viscose woven fabric. The “pillowcase” has binding around all four edges and an opening in the back for the insertion of the pillow typical of a pillow sham. The item will be imported in Standard (21 × 31 inches) and King (21 × 41 inches) sizes. The face of the item is clearly marked with the word “SAMPLE,” approximately 7 × 15 inches, using a permanent marker with indelible ink. Item # 3, Style # S 90649, is described as a quilt with an outer surface of 100 percent cotton woven fabric and filling of 100 percent polyester. The quilt measures 60 × 80 inches. The face of the quilt is clearly marked with the word “SAMPLE,” approximately 10 × 30 inches, using a permanent marker with indelible ink. Item # 4, Style # S 90933, is described as a decorative pillow with an outer surface of 100 percent polyester velvet plush fabric and filling of 100 percent polyester fiberfill. The pillow features a printed tartan plaid design and measures 18 × 18 inches. The face of the pillow is clearly marked with the word “SAMPLE,” approximately 3 × 5 inches, using a permanent marker with indelible ink.

You suggested that these articles are eligible for duty-free treatment under subheading 9811.00.60, Harmonized Tariff Schedule of the United States (HTSUS), which provides for the free entry of articles used in the U.S. as samples only to solicit orders for products of foreign countries, provided they are valued not over $1.00 each, or are marked, torn, perforated or otherwise treated so as to render them unsuitable for sale or for use otherwise than as samples. You state the imported items under consideration are valued over $1.00, are permanently marked with the word “SAMPLE,” and are imported for the purpose of soliciting orders for foreign merchandise. Based on the information submitted, we agree that the goods meet the requirements of subheading 9811.00.60, HTSUS. The applicable subheading for the pillows, “pillowcase” and quilt will be 9811.00.60, HTSUS, which provides for any sample (except samples covered by heading 9811.00.20 or 9811.00.40), valued not over $1 each, or marked, torn, perforated or otherwise treated so that it is unsuitable for sale or for use otherwise than as a sample, to be used in the United States only for soliciting orders for products of foreign countries. The rate of duty will be free. The tariffs and additional 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/. 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 Kim Wachtel at [email protected].
Sincerely,
(for) James Forkan Acting Director National Commodity Specialist Division