The tariff classification of an adjustable face support cradle and cushion device from China

N360899May 19, 2026CLA-2-94:OT:N2:349
CATEGORY: Classification
TARIFF NO.: 9404.90.2090
Dr. Peter KunsztGeschwister-Spitzer-Weg 2/1/17Vienna 1120AustriaRE: The tariff classification of an adjustable face support cradle and cushion device from ChinaDear Dr. Kunszt:In your letter dated
April 22, 2026
, you requested a tariff classification ruling. In lieu of a sample,photographs were submitted with your request.The subject article is described as an , for which you state a style name or SKU# has not yet been assigned,device designedo slide between a mattress and boxadjustable face support cradle and cushion tsecurely spring(or bed frame)support for the . The device extends outward from the mattress to provide ergonomic head and neck of a user lying during massages.he itemprone, relaxation, or therapeutic body treatments Tfeatures a aminated lywood framewith eightadjust andlp notches to allow for h ments a U-shapedpolyurethane (PU) cushion with a PU cover. The cushion is secured to the plywood frame with hook-and-loop .tabs The product does not contain any electronic or mechanical components and does notactively perform massage or therapeutic functions. You state the item will be imported as a complete,The adjustable face support device measuresfinished product and is ready for use without further assembly. 11.8 inches in height by 11.2 inches in width, and the -shaped cushion measures 11.8 inchesUapproximately in width y inche in thicknessb3s.The adjustable face support cradle and cushion device is a composite good consisting of a laminated plywoodframe (Heading 4421) and U-shaped cushion (Heading 9404). General Rule of Interpretation (GRI) 1,Harmonized Tariff Schedule of the United States (HTSUS), states in part that for legal purposes,classification shall be determined according to the terms of the headings, any relative section or chapter notesand, unless otherwise required, according to the remaining GRI’s taken in order. Goods that are, prima facie,classifiable under two or more headings, are classifiable in accordance with GRI 3. GRI 3(a) states that theheading which provides the most specific description shall be preferred to headings providing a more generaldescription. However, when two or more headings refer to part only of the items in a composite good, thoseheadings are to be regarded as equally specific in relation to the goods, even if one of them gives a morecomplete or precise description of the good. As such, they are regarded as equally specific and classification
of the composite good is to be determined by GRI 3(b) or GRI 3(c). GRI 3(b) states, in part, that compositegoods, which cannot be classified by reference to GRI 3(a), are to be classified as if they consisted of thecomponent which gives them their essential character. It is our opinion that the essential character of thisplywood frame merely acts the cushion.item is the polyurethane foam cushion. The to hold and positionThe applicable classification of the adjustable face support cradle and cushion device will be subheading9404.90.2090, HTSUS, which provides for “Mattress supports; articles of bedding and similar furnishing (forexample, mattresses, quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed orinternally fitted with any material or of cellular rubber or plastics, whether or not covered: Other: Pillows,cushions and similar furnishings: Other: Other.” The general rate of duty will be 6 percent ad valorem.The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenienceand are subject to change. The text of the most recent HTSUS and the accompanying duty rates are providedat https://hts.usitc.gov/.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to theclassification stated above, the merchandise covered by this ruling may also need to be reported with eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems 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 asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Kim Wachtel at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division