The tariff classification of a bowl clamp from China.

N363253
July 31, 2026
CLA-2-39:OT:RR:NC:N4:415
CATEGORY: Classification
TARIFF NO.: 3926.90.9989
Xinpeng Du Dymmoy 16263 Wind View Lane, Building 53 Winter Garden, FL 34787 RE: The tariff classification of a bowl clamp from China. Dear Mr. Du: In your letter dated July 10, 2026, you requested a tariff classification ruling. Images were provided in lieu of a sample. The product under consideration is described as the “Dymmoy Self-Feeding Bowl Clamp.” It is a reusable and washable feeding accessory designed for babies and toddlers that are six months of age and older. This article is used to secure a separate feeding bowl to a dining table or highchair tray during mealtimes to prevent the bowl from being pushed, lifted, tipped, or flipped while a child practices self-feeding under adult supervision. It can accommodate a bowl with a diameter of approximately 8 to 12 centimeters and in a variety of bowl shapes. The item is constructed primarily of acrylonitrile butadiene styrene (ABS) plastic along with internal metal components which support the internal adjustment and clamping mechanism. You suggest that this bowl clamp may be classifiable under subheading 3924.10.4000, Harmonized Tariff Schedule of the United States (HTSUS), as an other household article. We disagree as we hold the opinion this product is not of the same class or kind as the exemplars of tableware and kitchenware articles of plastics listed in EN 39.24 due to the fact this item functions as a clamp. Rather, we find this product to be similar to the one discussed in N269773, dated November 12, 2015, and we will classify this in the same manner. As the “Dymmoy Self-Feeding Bowl Clamp” would be considered an article of plastic, and as it is not more specifically provided for elsewhere, the applicable subheading will be 3926.90.9989, HTSUS, which provides for “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther.” The column one, general rate of duty is 5.3 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 CBP Regulations (19 CFR 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 Kristopher Burton at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division