N358156

N358156 February 12, 2026 CLA-2-94:OT:RR:NC:N4 410 CATEGORY: Classification TARIFF NO.: 9405.50.4000 Tung Nguyen Baker Hostetler LLP 1050 Connecticut Avenue NW, Suite 1100 Washington, DC 20036 RE: The tariff classification of hand-painted candles from Lithuania Dear Mr. Nguyen: In your letter dated January 23, 2026, you requested a tariff classification ruling made on behalf of Point One International Ltd. (dba Flatyz). Representative samples and descriptions of the merchandise were submitted for our review. The merchandise under consideration is four SKUs of candle lamps referred to as “Flatyz candles”. Each Flatyz candle consists of a wax candle and a steel candle stand/holder packaged together ready for retail sale. The Flatyz candles can be placed on any flat surface to illuminate the surrounding area. You state that each Flatyz candle is hand-poured and hand-painted in Lithuania, conveying a meaningful message based on the design that is hand-painted by candle artisans. Specifically: Item 1 SKU 18K036, Van Gogh Starry Night Candle The candle measures 6 inches in length, 2.25 inches in width and 0.25 inches in depth. The stand comprises a rectangular steel sheet measuring 2.5 inches by 2 inches with a U-shaped slot raised in the middle that is designed to stabilize or hold the candle in place securely. The candle is painted with the image of Van Gogh’s Starry Night with two wicks atop. Item 2 SKU D22036, Happy Hanukkah Candle Item 2 is similar to Item 1 SKU 18K036 in construction, but the candle is painted with the images of lit candles, the Star of David and “Happy Hanakka”. Item 3 SKU Q25D22, Happy Birthday Cake with Sprinkles Candle The square-shaped candle measures 5.5 inches by 5.5 inches and 0.25 inches in depth with four wicks atop. The stand is made of a steel sheet measuring 6 inches in width and 1.5 inches in depth. The left side of the stand is extended upward and then bent horizontally forming a design structure to hold and secure the candle. Item 4: SKU R24D09, Christmas Tree in Window Candle Item 4 is similar to Item 3 in construction. The candle is in a round shape of a diameter of 5.5 inches with three wicks atop and painted with an image depicting a decorated Christmas tree behind the window. In your request, you state that you believe the Flatyz candles should be classified under subheading 3406.00.0000, Harmonized Tariff Schedule of the United States (HTSUS), as candles. We disagree. As these products feature candles with metal stands designed to hold and secure the wax candles in place, we are of the opinion that they are more appropriately described as non-electric candle lamps of heading 9405. Thus, classification within heading 3406, HTSUS, as proposed, would not be appropriate, General Rule of Interpretation 1 noted. The applicable subheading for the four SKUs of Flatyz candles will be 9405.50.4000, HTSUS, which provides for “Luminaires and lighting fittings including searchlights and spotlights and parts thereof, not elsewhere specified or included; illuminated signs, illuminated nameplates and the like, having a permanently fixed light source, and parts thereof not elsewhere specified or included: Non-electrical lamps and lighting fittings: Other: Other.” The column one, general rate of duty will be 6 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 Frequently Asked Questions on the Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ. 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 Michael Chen at michael.w.chen@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division

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 Michael Chen at michael.w.chen@cbp.dhs.gov. 
Sincerely,
 (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division