The tariff classification of locker kits from China

N361582June 8, 2026CLA-2-94:OT:RR:NC:N5:433
CATEGORY: Classification
TARIFF NO.: 9403.89.6015
Rhonda Riley-ThayerSupply Chain Solutions, LLC4607 44th St. SEGrand Rapids, MI 49512RE: The tariff classification of locker kits from ChinaDear Ms. Riley-Thayer:In your letter dated
May 8, 2026
, you requested a tariff classification ruling on behalf of Feradyne OutdoorsLLC. In lieu of samples, technical and illustrative literature and product descriptions were provided forreview.Item 1, the “Scent Crusher Locker” and item 2, the “Scent Crusher Locker Lite” are floor standing steel metalframe storage locker kits. The lockers shelving components will provide storage and organization of huntinggear, sports equipment, and athletic gear. Each storage locker kit will incorporate metal rails, brackets,adjustable wire mesh shelving components, polyester textile fabric zipper enclosures, and a battery-operatedozone generator unit. The ozone generator component, referred to as the common generator, consists ofPrinted Circuit Board Assembly (PCBA), ceramic corona plate, and a rechargeable battery within a plasticenclosure. The common generator functions by drawing in air and passing it through the corona plate. Theplate introduces an electrical charge to the air, which creates charged oxygen, or ozone. This ozone is used tosterilize and remove odors. The Scent Crusher Locker dimensions are approximately 45" in width, 69" inheight, and 27" in depth. The Scent Crusher Locker Lite dimensions are approximately 28" in width, 69" inheight, and 20" in depth. The ruling request seeks classification of item 1 and item 2 in subheading 8543.70.9860, Harmonized TariffSchedule of the United States (HTSUS). We disagree.The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitutes theofficial interpretation of the Harmonized System at the international level.EN X to General Rule of Interpretation (GRI) 3(b) provides: “for the purposes of this Rule, the term “goodsput up in sets for retail sale” shall be taken to mean goods which: (a) consist of at least two different articleswhich are, prima facie, classifiable in different headings; (b) consist of products or articles put up together to
meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directlyto end users without repacking (e.g., in boxes or cases or on boards).” Sets are classified according to thecomponent, or components taken together, which can be regarded as conferring on the set as a whole itsessential character. The “Scent Crusher Locker” and the “Scent Crusher Locker Lite” will each consist of two different articlesthat are classifiable in different headings [ozone generator/8543, locker/9403]; are put together to meet aparticular need or carry out a specific activity [odor elimination, vertical and horizontal storage andorganization], and will be suitable for sale directly to end users without repacking. The “Scent CrusherLocker” and the “Scent Crusher Locker Lite” will each be considered a set for customs purposes. Further, EN XII to GRI 3(c) provides in part: “when goods cannot be classified by reference to Rule 3(a)specific description or 3(b) essential character, they are to be classified in the heading which occurs last innumerical order among those which equally merit consideration in determining their classification.” The ozone generator component removes odors. The metal frame locker encased in breathable textile fabricis furniture that will provide for the vertical and horizontal storage and organization of athletic gear, sports,and hunting equipment. The textile fabric of each storage locker creates the breathable enclosed environmentfor the capture and removal of odors when used in conjunction with the ozone generator unit. Collectively,no essential character can be determined because no one single component is more important than the next. The “Scent Crusher Locker” and the “Scent Crusher Locker Lite” will be classified in the heading whichoccurs last in numerical order. In this case, the heading 9403 Harmonized Tariff Schedule (HTS) is last.The applicable subheading for the “Scent Crusher Locker” and the “Scent Crusher Locker Lite” will be9403.89.6015, HTSUS, which provides for “Other furniture and parts thereof: Furniture of other materials,including cane, osier, bamboo or similar materials: Other: Other: Other household.” The general rate ofduty will be free.The 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 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 the classification 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 Dharmendra Lilia at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division