The tariff classification of a wooden cutting board from China

N363968August 13, 2026CLA-2-44:OT:RR:NC:N5:130
CATEGORY:Classification
TARIFF NO.: 4419.20.9000
Ms. Jennifer CharneyPrincess House20 Cabot Blvd.Suite 105Mansfield, MA02048 RE:The tariff classification of a wooden cutting board from China Dear Ms. Charney:In your letter, dated
August 3, 2026
, you requested a binding tariff classification ruling on a wooden cuttingboard with storage system.Product information and photos were submitted for our review. The product under consideration is Item 10762 PH Prep Cutting Board System.The item is a two-sided acacia wood (., a tropical wood) cutting board with a removable steel strainer, two removable steelAcacia sppstorage bins with lids, and a removable steel support rack. The cutting board is composed of multiple separable items that are classifiable in different headings.The Explanatory Notes to the Harmonized System (ENs) indicate that a composite good may be “separablecomponents, these components are adapted one to the other and are mutually complementary andprovidedthat together they form a whole which would not normally be offered for sale in separate parts.”This describes the instant cutting board system.It is therefore a composite good classifiable in accordance with GRI 3(b).The ENs, General Rules of Interpretation (GRI) 3(b) (VIII), state that “the factor which determines essential character will vary between different kinds of goods. It may for example, be determinedby the nature of the materials or components, its bulk, quantity, weight or value, or by the role of aconstituent material in relation to the use of the goods.” When the essential character of a composite good canbe determined, the whole product is classified as if it consisted only of the material or component thatimparts the essential character to the composite good.The wooden cutting board is the main component of the cutting board system, not only by weight and value,but by function.It is the component that imparts the main use and the strainer, storage bins, and support rack are secondary to the use of the cutting board.Therefore, the wooden cutting board imparts the essential character of the cutting board system.
In your letter, you suggest the cutting board is classifiable under subheading 4419.90.9100, HarmonizedTariff Schedule of the United States (HTSUS) which provides for kitchenware of wood other than bamboo ortropical wood.We disagree.The cutting board is made of acacia wood, which is identified as a tropical wood within the Appellation of Certain Tropical Woods in the ENs to Chapter 44.The applicable subheading for Item 10762 PH Prep Cutting Board System will be 4419.20.9000, HTSUS,which provides for Tableware and kitchenware, of wood: Oftropical wood: Other.The general rate of duty will be 3.2 percent ad valorem. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to theclassification stated above, the merchandise covered by this ruling may also need to be reported with eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems Messaging Service (CSMS) messages at and the Trade Remedies page at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service.https://www.cbp.gov/trade/programs-administration/trade-remediesThe holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Laurel Duvall at [email protected]
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division