The tariff classification of an electric heating pad from China

N361988
June 30, 2026
CLA-2-63:OT:RR:NC:N3:351
CATEGORY: Classification
TARIFF NO.: 6307.90.9891
Ms. Nicole Robertson Berkshire Blanket 446 Main Street Worcester, MA 01608 RE: The tariff classification of an electric heating pad from China Dear Ms. Robertson: In your letter dated June 2, 2026, you requested a tariff classification ruling. A sample of the product was provided to this office and will be retained for training purposes. The sample, identified as a “Heating Pad” is a Berkshire® electric heating pad designed to be worn over the wearer’s shoulders, neck, and back and is intended to provide heat therapy to relax tight muscles and warmth. The heating pad is composed of four layers consisting of: a top and bottom outer shell of 100 percent polyester knitted plush, dyed, fabrics; a second layer of 100 percent polyester nonwoven needle-punched fabric; and a third layer of 100 percent polyester nonwoven needle-punched fabric bonded to heating wire. When laid flat, the cape-like heating pad measures 26 inches in width and 34 inches in length. When worn, it provides a contoured fit measuring 23 inches across the shoulders and 28 inches in height. It features two sets of snap buttons in the center front to secure the item around the shoulders and a 1 ½ inch wide by 23-inch-long self-fabric strap sewn to either side designed to be tied across the abdomen. The heating pad is kept in place by glass beads partially incorporated along the edges of the collar and the bottom edge of the pad. The heating pad also features a detachable handheld controller with ten temperature settings and three timer options ranging from one to three hours, with a two-hour auto-off safety default setting. You have suggested that the heating pad should be classified under subheading 8516.79.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "other electrothermic appliances of a kind used for domestic purposes, other electrothermic appliances, other." We disagree. Our review of the sample and the information in your submission, including subsequent email correspondence, suggests that the heating pad is designed to be worn on or around the person. Note 1(a) to Chapter 85 states: "This chapter does not cover: Electrically warmed blankets, bed pads, foot-muffs or the like; electrically warmed clothing, footwear or ear pads or other electrically warmed articles worn on or about the person." Therefore, classification under subheading 8516.79.0000 is precluded.

The applicable subheading for the “Heating Pad” will be 6307.90.9891, HTSUS, which provides for “Other made-up articles, including dress patterns: Other: Other: Other: Other: Other.” The rate of duty will be 7 percent ad valorem. 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 provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties 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 either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems 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 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 Kristine Dodge at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division