RE: The tariff classification of plastic dish racks 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 N364065 September 1, 2026 CLA-2-39:OT:RR:NC:N4:422 CATEGORY: Classification TARIFF NO.: 3924.90.5650 Katherine Dobscha Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP 599 Lexington Ave. New York, NY 10022 RE: The tariff classification of plastic dish racks from China Dear Ms. Dobscha: In your letter dated August 5, 2026, on behalf of your client, Simplehuman, LLC, you requested a tariff classification ruling. Photographs and three samples (KT1181, KT 1184DC, and KT2103) were submitted with your request. The importer’s website was also reviewed. The three samples will be returned to you as requested. The five items are Simplehuman steel frame dish racks, SKUs KT1181, KT 1184DC, KT1197, KT1198, and KT2103. In an e-mail to this office received on August 18, 2026, you confirmed that the country of origin for all five dish racks is China. The five dish racks are made of plastic and steel components. The items are placed on a kitchen countertop near the sink and are intended for household use. The articles are designed to hold plates, bowls, glasses, and cutlery for drying. SKU KT1181 measures approximately 22.30 inches long by 11.50 inches high by 10.50 inches wide. It includes a plastic dish rack, plastic basin, plastic tray stand with a plastic drain spout, plastic side drip tray, four plastic feet, and a plastic utensil holder. The dish rack sides are made of steel. The exterior features four U-shaped steel wire glass/cup holders and a steel wire to hold wine glasses. A removable steel wire rack rests inside the dish rack. SKU KT1184DC measures approximately 15.00 inches long by 6.50 inches high by 7.00 inches wide. It includes a plastic dish rack, plastic basin, plastic tray stand with a plastic drain spout, plastic side drip tray, four plastic feet, and a plastic utensil holder. The dish rack sides are made of steel. The exterior features two U-shaped steel wire glass/cup holders and a steel wire to hold wine glasses. A removable steel wire rack rests inside the dish rack.
SKU KT1197 measures approximately 22.30 inches long by 11.50 inches high by 10.50 inches wide. It includes a plastic dish rack, plastic basin, plastic tray stand with a plastic drain spout, plastic side drip tray, four plastic feet, and a plastic utensil holder. The dish rack sides are made of steel. The exterior features four U-shaped steel wire glass/cup holders and a steel wire to hold wine glasses. A removable steel wire rack rests inside the dish rack. SKU KT1198 measures approximately 22.30 inches long by 11.50 inches high by 10.50 inches wide. It includes a plastic dish rack, plastic basin, plastic tray stand with a plastic drain spout, plastic side drip tray, four plastic feet, and a plastic utensil holder. The dish rack sides are made of steel. The exterior features four U-shaped steel wire glass/cup holders and a steel wire to hold wine glasses. A removable steel wire rack rests inside the dish rack. SKU KT2103 measures approximately 20.00 inches long by 6.50 inches high by 13.50 inches wide. It includes a plastic dish rack, plastic basin, plastic tray stand with a plastic drain spout, plastic side drip tray, four plastic feet, a plastic utensil holder and a seven-slot plastic knife block. The plastic knife block is inserted into the plastic utensil holder. The dish rack sides are made of steel. The exterior features four U-shaped steel wire glass/cup holders and a steel wire to hold wine glasses. A removable steel wire rack rests inside the dish rack. The items are considered composite goods within the meaning of General Rule of Interpretation (GRI) 3. The household kitchen dish racks are made of plastic and steel components. The plastic components make up the majority of the weight, bulk, and structure of the household kitchen dish racks. The plastic components provide the principal function of the kitchen dish racks. Therefore, it is the opinion of this office that the plastic components provide the essential character within the meaning of GRI 3(b). You propose classifying all five dish racks under subheading 3924.10.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Tableware, kitchenware, other household articles and hygienic or toilet articles, of plastics: Other.” However, as discussed on our TEAMS conference call on August 17, 2026, this office indicated that the dish racks are not considered tableware or kitchenware articles of plastics. During our phone call, this office stated that the plastic dish racks were considered other household articles of plastics. This was based on NY rulings R04000, issued June 19, 2006, and R03996, issued June 21, 2006, which both rulings classified plastic dish racks as other household articles of plastics, other. Based on these two precedents, it was indicated to you that the five dish racks would be classified as an other household article of plastic, other in subheading 3924.90.5650, HTSUS. Therefore, classification in subheading 3924.10.4000, HTSUS, is precluded. The applicable subheading for the five plastic dish racks, SKUs KT1181, KT 1184DC, KT1197, KT1198, and KT2103, will be subheading 3924.90.5650, HTSUS, which provides for “Tableware, kitchenware, other household articles and hygienic or toilet articles, of plastics: Other: Other. Other.” The general rate of duty will be 3.4 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 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 Dana L. Salas at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division