The tariff classification of a sofa sectional storage console from Vietnam

N362229
June 24, 2026
CLA-2-94:OT:RR:NC:N5:433
CATEGORY: Classification
TARIFF NO.: 9401.61.6011
Melissa Birch Radiant World Trade Services 1300 Mendota Heights Rd Mendota Heights, MN 55120 RE: The tariff classification of a sofa sectional storage console from Vietnam Dear Ms. Birch: In your letter dated June 10, 2026, you requested a tariff classification ruling on behalf of Kuka (HK) Trade Co. Ltd. In lieu of samples, technical and illustrative literature, a product description, and a manufacturing synopsis were provided for review. Item 1987687, the “Leather Storage Console with Hidden Cupholders,” is a modular sofa sectional unit. The upholstered sofa sectional unit is constructed of leather, foam, polyester fiber, and polyvinyl chloride (PVC) that is affixed to a wooden frame. The wooden frame consists of engineered wood materials that include (1) plywood, (2) laminated veneer lumber (LVL) and Southern pine wood. The modular sofa sectional unit will have USB-A and USB-C charging ports and a storage compartment with a pair of cupholders. The modular sofa sectional seating unit contains assembly hardware in the form of connection posts and/or connection clips for integration and assembly onto additional sofa sectional units (sold separately). The modular sofa sectional unit dimensions are approximately 40.5" in length, 12.5" in width, and 26.3" in height. The ruling request seeks classification of the subject merchandise in subheading 9403.60.8093 of the Harmonized Tariff Schedule of the United States (HTSUS). We disagree. The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitutes the official interpretation of the Harmonized System at the international level. EN I to General Rule of Interpretation (GRI) 2(a) provides: “the first part of Rule 2(a) extends the scope of any heading which refers to a particular article to cover not only the complete article but also that article incomplete or unfinished, provided that, as presented, it has the essential character of the complete or finished article.”

EN V to GRI 2(a) provides: “the complete or finished articles presented unassembled or disassembled are to be classified in the same heading as the assembled article. When goods are presented, it is usually for reasons such as requirements or convenience of packing, handling or transport.” The “Leather Storage Console with Hidden Cupholders” at issue, though incomplete without being connected, is nevertheless dedicated to a sofa sectional. The sofa sectional component does not have any commercial reality apart from being connected into an assembled sofa. Chapter 94, Legal Note 2, 2(a), and 2(b) provides: “articles (other than parts) referred to in headings 9401 to 9403 are to be classified in those headings only if they are designed for placing on the floor or ground. The following are, however, to be classified in the above-mentioned headings even if they are designed to be hung, to be fixed to the wall or to stand one on the other: 2(a) Cupboards, bookcases, other shelved furniture (including single shelves presented with supports for fixing them to the wall) and unit furniture. 2(b) Seats and Beds.” The “Leather Storage Console with Hidden Cupholders” is designed to be placed on the floor or ground, is designed to be placed side-by-side additional sofa sectional components and is designed to be configured or reconfigured within a multi-piece sofa sectional. The “Leather Storage Console with Hidden Cupholders” falls within the construct of Chapter 94, Legal Note 2, 2(a), and 2(b). Further, the ENs to Chapter 94, heading 9401 of the Harmonized Tariff Schedule (HTS), states: “lounge chairs, arm-chairs, folding chairs, desk chairs, infants’ high chairs and children’s seats designed to be hung on the back of other seats (including vehicle seats), grandfather chairs, benches, couches (including those with electrical heating, settees, sofas, ottomans and the like, stools (such as piano stools, draughts men’s stools, typists’ stools, and dual purpose stool-steps), seats which incorporate a sound system and are suitable for use with video game consoles and machines, television or satellite receivers, as well as with DVD, music CD, MP3 or video cassette players” as exemplars for seats classified in heading 9401, HTS. “Seats of this heading may incorporate complementary non-seat components, for example, toy components, a vibration function, music or sound players, as well as lighting features.” The “Leather Storage Console with Hidden Cupholders” is within the construct of the ENs to heading 9401 HTS for seats. The upholstered sofa sectional unit is a dedicated seating component that will be integrated within a line of sofa sectionals. The connection posts and/or connection clips will allow other sofa sectional seating components to be interlinked and create different modular seating configurations. The applicable subheading for the subject merchandise will be 9401.61.6011, HTSUS, which provides for “Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Other seats, with wooden frames: Upholstered: Other: Other household.” The general rate of duty 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 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 Dharmendra Lilia at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division