The tariff classification of sectional sofa components from Vietnam

N362411
June 30, 2026
CLA-2-94:OT:RR:NC:N5:433
CATEGORY: Classification
TARIFF NO.: 9401.61.6011
Paula Connelly Sandler Travis & Rosenberg, P.A. 100 Trade Center, Suite G-700 Woburn, MA 01801 RE: The tariff classification of sectional sofa components from Vietnam Dear Ms. Connelly: In your letter dated June 17, 2026, you requested a tariff classification ruling on behalf of Bob’s Discount Furniture. In lieu of samples, technical and illustrative literature, product descriptions, and a manufacturing synopsis were provided for review. Item 1, the “Play Day Pop-Up Loveseat – Left Facing (LF),” item 2, the “Aspen Pop-Up Sofa - LF,” and item 3, the “Aspen Armless Pop-Up Sofa” are modular sectional seating components. The sectional seating components do not incorporate integrated full-size folding mattress components. Information provided states, (1) “[T]he units in question are not sold separately and are only offered for sale as part of a modular sectional,” and (2) the individual seating components are constructed of memory foam cushions, elastic banding, polyester upholstered fabric affixed to wooden frames, and metal pop-up recline mechanisms. The individual seating components contain assembly hardware in the form of connection posts and/or connection clips for integration and assembly onto additional sectional units (sold separately). Information provided conveys that the seats will create larger seating units and may be made available for retail sale as 2-piece units, 3-piece units, 4-piece units, and other seating configurations. The ruling request seeks classification of items 1, 2, and 3 in subheading 9401.41.0000 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.” Items 1, 2, and 3 are sectional seating components, although incomplete sections, each model is nevertheless a dedicated component to a larger unified single sofa sectional. Each seating component has unfinished corners and does not have any commercial reality apart from being connected and assembled with other sectional seating components. Further, 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.” Items 1, 2, and 3 are designed to be placed on the floor or ground, are designed to be placed side-by-side additional sofa sectional components, and are designed to be integrated, configured, or reconfigured within multi-piece sofa sectional seating systems. The assembly hardware that is comprised of connection posts and/or connection clips will allow other sofa sectional seating components to be interlinked and the ability to create a variety of functional and versatile modular sectional seating arrangements. (See Headquarters 084134 dated June 12, 1989, New York Ruling Letter (NYRL) NY N169339 dated June 22, 2011, NY N213815 dated May 15, 2012, N338074 dated February 28, 2024, and NY N338705 dated April 3, 2024). The applicable subheading for items 1, 2, and 3 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