RE: The tariff classification of a wooden furniture component from China

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 N363991 August 19, 2026 CLA-2-94:OT:RR:NC:N5:433 CATEGORY: Classification TARIFF NO.: 9403.91.0080 Laurent Soria Arioss LLC. 1209 Mountain Road Pl NE, Suite R Albuquerque, NM 87110 RE: The tariff classification of a wooden furniture component from China Dear Mr. Soria: In your letter dated August 4, 2026, you requested a tariff classification ruling. In lieu of samples, technical and illustrative literature, a product description, and a manufacturing synopsis were provided for review. The “Outdoor Mounting Kit” is a wood and metal ground support anchor that will function as a pedestal base for the Little Free Library (sold separately). The kit will consist of (1) a pressure-treated pine wood upper mounting plate that will attach to the post, (2) a decorative pressure-treated pine wood post, (3) a black powder-coated galvanized steel helical ground anchor that will be screwed directly into the soil, and (4) assembly hardware. The mounting plate will have a laser engraved phrase that states, “Take a book & Leave a book.” The mounting plate measures approximately 28cm in length, 19cm in width, and 7.6cm in height. The wooden post will have a flat full face and sloped recessed panel inserts on each side. The wooden post measures approximately 800mm in length and 89mm in width. The tapered anchor measures approximately 7cm in diameter and 68.5cm in length. The kit will mount to the Little Free Library and is intended to be installed above ground in a garden or in front of a private residence where members of the community may freely leave and take books. In the condition at the time of importation into the United States, the kit will be packaged together and offered for retail sale as one unit. The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitutes the official interpretation of the Harmonized System at the international level. The ENs to Chapter 94 of the Harmonized Tariff Schedule (HTS), for “Parts,” provides: “This Chapter only covers parts, whether or not in the rough, of goods of heading 9401 to 9403 and 9405, when identifiable by their shape or other specific features as parts designed solely or principally for an article of those headings. They are classified in this Chapter when not more specifically covered elsewhere.”
Further, Chapter 94, Legal Note 2 provides: “The 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 restriction on “furniture” being floor or ground standing does not apply to (parts) of furniture. In view of the facts provided, the upper plate of the “Outdoor Mounting Kit” will attach to the Little Free Library’s wooden storage box, the wooden post, the metal ground anchor, and will further provide structure and support for the Little Free Library’s wooden box as books are borrowed and returned. The subject merchandise is therefore within the construct of the Chapter 94 ENs for parts. The “Outdoor Mounting Kit” (a) consists of at least two different articles which are, prima facie, classifiable in different headings [metal anchor, wooden mounting plate and post]; (b) consists of products or articles put together to meet a particular need or carry out a specific activity [support]; and (c) are put up in a manner suitable for sale directly to end users without repacking, therefore, the subject merchandise will be considered a set for customs purposes. Additionally, the decorative and laser engraved wood components are the indispensable attribute that strongly marks or serves to distinguish the structure, core or condition of the article. The essential character of the “Outdoor Mounting Kit” as a whole is imparted by the wood components. The applicable subheading for the subject merchandise will be 9403.91.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other furniture and parts thereof: Parts: Of wood: Other.” 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