RE: The tariff classification, country of origin, marking, and eligibility for preferential treatment under the United States-Mexico-Canada Trade Agreement (“USMCA”) of a forklift dust mop attachment

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N363381 August 17, 2026 CLA-2-96:OT:RR:NC:N4:462 CATEGORY: Classification; Origin; Marking; Trade Programs TARIFF NO.: 9603.90.8050 Mark Johnson McClary, Swift & Co. – Blaine, Inc. 8105 Birch Bay Square Street, Suite 201 Blaine, WA 98230 RE: The tariff classification, country of origin, marking, and eligibility for preferential treatment under the United States-Mexico-Canada Trade Agreement (“USMCA”) of a forklift dust mop attachment Dear Mr. Johnson: In your letter dated July 16, 2026, you requested a ruling regarding the tariff classification, country of origin, marking, and eligibility for preferential treatment under the USMCA on behalf of your client, Fleetman Consulting Inc. Images and product literature were provided in lieu of a sample. The product under consideration is described as the “TigerMop,” a forklift dust mop attachment designed to sweep and clean large warehouse floors. The TigerMop is comprised of a dust mop, a mop frame, a hitch system, and a securing chain. The rectangular dust mop is comprised of cotton yarn with a synthetic backing material made of rayon, acrylic, and polyester. The backing material features openings allowing it to fit onto a rectangular mop frame made of steel that is available in widths of 48”, 60”, or 72”. A separate steel hitch system, which enables attachment of the mop head to a forklift, includes fork pockets, cross tubes, a pivoting boom, a round puck-style neodymium magnet (the “magnetic clutch”), mounting pins, and miscellaneous fasteners. The mop head attaches to the hitch system via the magnet and mounting pins on the pivoting boom. Without the dust mop frame installed, the hitch system measures 20” in width, 29 5/16” in depth, and 9” in height. A forklift operator would drive up to the dust mop attachment, slide the forks into the fork pockets, lift the attachment to knee height, then secure it to the forklift using the securing chain. The magnetic clutch feature facilitates controlled, 360-degree horizontal rotation of the dust mop frame, either left or right, in the event the outer edges of the dust mop frame are impacted by resistance or an obstruction. The TigerMop does not use hydraulics or electricity to operate.
Per your submission, the mop is manufactured in the US using materials that originate in Vietnam. In the US, the polyester backing is cut and slits are made to allow for insertion of the mop frame, while a hole is cut in the center where the pivoting boom can be attached. Yarn is sewn onto the polyester backing with thread before the mops are shipped to Canada. The steel mop frame and hitch system are manufactured in Canada using materials sourced from various countries, including the US, UAE, China, Indonesia Taiwan, Malaysia, and Canada. In Canada, fabricators cut and/or fabricate the individual components, which are then sent out for powder coat painting. Final assembly of all components takes place, followed by quality control and shipping preparation. The mop and hitch system are then exported to the U.S. as one complete assembled unit. CLASSIFICATION In your request, you suggest classification under subheading 9603.90.8050, Harmonized Tariff Schedule of the United States (HTSUS) as a mop. We agree. The applicable subheading for the “TigerMop” will be 9603.90.8050, HTSUS, which provides for “Brooms, brushes (including brushes constituting parts of machines, appliances or vehicles), hand-operated mechanical floor sweepers, not motorized, mops and feather dusters; prepared knots and tufts for broom or brush making; paint pads and rollers; squeegees (other than roller squeegees): Other: Other: Other.” The general rate of duty will be 2.8% 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/. ORIGIN AND MARKING Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other USMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in sections 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect to goods imported from Canada and Mexico. Section 102.11 provides a required hierarchy for determining the country of origin of a good for marking purposes, with the exception of textile and apparel goods which are subject to the provisions of 19 CFR 102.21. See 19 CFR 102.11. Applied in sequential order, 19 CFR 102.11(a) provides that the country of origin of a good is the country in which: (1) The good is wholly obtained or produced; (2) The good is produced exclusively from domestic materials; or (3) Each foreign material incorporated in that good undergoes an applicable change in tariff classification set
out in section 102.20 and satisfies any other applicable requirements of that section, and all other requirements of these rules are satisfied. Sections 102.11(a)(1) and 102.11(a)(2) do not apply to the facts presented in this case because the TigerMop is neither wholly obtained nor produced exclusively from “domestic” materials. Accordingly, we look to section 102.11(a)(3). The applicable tariff shift requirement in section 102.20 reads, “a change to heading 9603 from any other heading.” A mop is basically comprised of two components: a mop head and a mop handle. Customs has determined that neither of these components is substantially transformed by their attachment to one another and that each piece must be separately marked to indicate its country of origin. See HQ 733632, dated August 13, 1990. The mop in the instant ruling is comprised of materials of Vietnamese origin which undergo a tariff shift to heading 9603, HTSUS, to create the mop in the US, therefore its country of origin is the US. Goods of US origin need not be marked. The mop frame and the hitch system, i.e., the mop handle, incorporate foreign-origin materials which all undergo a change in tariff classification to heading 9603, HTSUS, when processed in Canada to form the mop handle. Therefore, the tariff shift requirement of section 102.11(a)(3) is met. In accordance with 19 CFR § 102.11(a), Rule (3), the country of origin of the steel hitch system for the 19 U.S.C. 1304 marking requirements is Canada. USMCA The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note ("GN") 11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11(b) states: For the purposes of this note, a good imported into the customs territory of the United States from the territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the tariff schedule as a "good originating in the territory of a USMCA country" only if- (i) the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries; (ii) the good is a good produced entirely in the territory of one or more USMCA countries, exclusively from originating materials; (iii) the good is a good produced entirely in the territory of one or more USMCA countries using non-originating materials, if the good satisfies all applicable requirements set forth in this note (including the provisions of subdivision (o)); Since the materials used in the production of the mop, mop frame, and hitch system are non-originating, the TigerMop is not considered a good wholly obtained or produced entirely in a USMCA country under GN 11(b)(i), nor is the product produced exclusively from originating materials per GN 11(b)(ii). Thus, we must determine whether the product qualifies under GN 11(b)(iii). As previously noted, the complete TigerMop is classified under subheading 9603.90.8050, HTSUS. The applicable rule of origin for goods classified under this subheading is in GN 11(o), which provides in relevant part: Chapter 96 (1), “A change to headings 9601 through 9605 from any other chapter.” Based on the documentation submitted, a tariff shift occurs with all foreign-origin components used to produce the mop in the US and the mop frame and hitch system in Canada. They are all classified in a chapter other than 96, HTSUS, at the time of importation. Therefore, the requisite tariff shift rule under GN 11(o), rule 1 to chapter 96, HTSUS, is met. As the TigerMop meets the necessary rules to qualify as originating, it would also qualify for preferential treatment under the USMCA.
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 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 Sandra Walia at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division