N358786

N358786 March 12, 2026 CLA-2-94:OT:RR:NC:N5:433 CATEGORY: Classification TARIFF NO.: 9403.20.0090; 9817.00.96 Michele Lehat Grunfeld Desiderio Lebowitz Silverman & Klestadt LLP 599 Lexington Ave, Fl 36 New York, NY 10022 RE: The tariff classification and eligibility under the Nairobi Protocol of metal furniture from the United Kingdom. Dear Ms. Lehat, Esq: In your letter dated February 11, 2026, you requested a binding tariff classification ruling on behalf of Bobrick Washroom Equipment, Inc. In lieu of samples, technical and illustrative literature, and product descriptions were provided for review. Item 1, the “KB2600 Height Adjustable Shower Changing Table” and item 2, the “KB3000-AHL Adjustable Height Changing Station” are a series of wall mounted height adjustable changing tables. Information provided conveys item 1 and item 2 will be wall mounted and permanently affixed to the structural frames in buildings and are “…designed to enhance accessibility in public and commercial facilities, such as schools, universities, airports, museums, recreational centers, stadiums, and arenas, by offering a functional changing solution beyond what standard restrooms provide.” Item 1 and item 2 are constructed of steel and aluminum metal frame rails, electro-mechanical height adjustable lift mechanisms, and a polyethylene plastic stretcher table. The electro-mechanical components allow the plastic stretcher table component to adjust in elevation according to caregiver or end-user preference, support the weight of the end user, and to be stowed away when not in use. The “KB2600 Height Adjustable Changing Table” dimensions approximate 60 7/16" in height, 70 55/64" in width, 49 31/64" in depth, and has a weight capacity of 440 lbs. Information provided states, “[T]he product is intended to be used by people trained or experienced in healthcare for a family member or client that: (1) needs to be changed or cleaned in a lying position, (2) is older and/or larger than a child able to use a standard baby changing facility, and (3) is likely to require a hoist to transfer to the changing table.” The changing station is powered by 110-240 volt control system with a battery backup. The “KB3000-AHL Adjustable Height Changing Station” dimensions approximate 75.25" in length, 31.5" in width, an adjustable height range from 12-41", and has a weight capacity of 500 lbs. The binding ruling request seeks classification of the subject merchandise in subheading 9403.70.8015 of the Harmonized Tariff Schedule of the United States (HTSUS). We disagree. The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitutes the official interpretation of the Harmonized System at the international level. The HTS, Chapter 94, Legal Note 2, 2(a) and 2(b) provides: “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 following are, however, to be classified in the above-mentioned headings even if they are designed to be hung, to be fixed to the wall or to stand one on the other: 2(a) Cupboards, bookcases, other shelved furniture (including single shelves presented with supports for fixing them to the wall) and unit furniture. 2(b) Seats and Beds.” A review of the facts finds item 1 and item 2 fall within the construct of Chapter 94, Legal Note 2, 2(a) and 2(b). The subject merchandise will be affixed to a wall, the stretcher table components will unfold and present a flat surface for the use by caregivers, adolescents, and adults for hygienic care, and the plastic stretcher table components will stow when not in use. Further, EN VIII to General Rule of Interpretation (GRI) 3(b) provides: “the factor which determines essential character will vary as between different kinds of goods. It may, for example, be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the goods.” When the essential character of a composite good can be determined, the whole product is classified as if it consisted only of the material or component that imparts the essential character to the composite good. U.S. Customs and Border Protection (CBP) has generally ruled that the composition of the tabletop or desktop imparts the essential character to a table or desk, noting that their primary purpose is most directly fulfilled by their top surface, where activities are performed and/or objects are placed. However, in New York Ruling Letter (NYRL) N334127, novelty tables that were made to look like a motorcycle, a biplane and a vintage car with metal frames and wooden tabletops were classified as metal tables, because of their metal frames. In NYRLs N270868 and N271412, desk extenders, with scissor-type lifting mechanisms, placed atop a table or desk to convert a standard desk into a standing desk were classified as metal table parts, based on their metal frames and not their wood tabletops. In NYRL N343588, CBP determined that the essential character of an adjustable-height gaming desk was imparted by the desk’s more expensive, heavier, more complex and functionally important variable-height metal chassis. For item 1, the “KB2600 Height Adjustable Shower Changing Table,” the plastic stretcher table component is 24% of the material cost. The metal frame height adjustable lift mechanism is 76% of the material cost. The plastic stretcher table component is 28% of the product’s total weight. The metal frame height adjustable lift mechanism is 72% of the product’s total weight. The plastic stretcher table component measures 70.9” in length, 31.5” in width and is supported by a 1.5” x 0.12” and 1.25” x 0.08” in diameter metal rail surround. For item 2, the “KB3000-AHL Adjustable Height Changing Station,” the plastic stretcher table component is 41% of the material cost. The metal frame height adjustable lift mechanism is 59% of the material cost. The plastic stretcher table component is 40% of the product’s total weight. The metal frame height adjustable lift mechanism is 60% of the product’s total weight. The plastic stretcher table component measures 74.25” in length, 31.5” in width, and is supported by a 2”x 2” x 0.12” metal rail surround. In view of the facts provided and considering the functionality, bulk, cost, and weight, this office finds that the metal chassis and the incorporated metal lifting mechanism is the indispensable attribute that strongly marks or serves to distinguish the structure, core or condition of each item. The essential character of item 1 and item 2, as a whole, is imparted by the metal components. The applicable subheading for item 1 and item 2 will be 9403.20.0090, HTSUS, which provides for “Other furniture and parts thereof: Other metal furniture: Other: Other.” The general rate of duty will be free. Nairobi Protocol: In your submission you also requested consideration of a secondary classification under 9817.00.96, HTSUS, which applies to articles and parts of articles specifically designed or adapted for the use or benefit of the permanently or chronically physically or mentally handicapped. Subheading 9817.00.96, HTSUS, covers: “Articles specially designed or adapted for the use or benefit of the blind or other physically or mentally handicapped persons; parts and accessories (except parts and accessories of braces and artificial limb prosthetics) that are specially designed or adapted for use in the foregoing articles . . . Other.” The term “blind or other physically or mentally handicapped persons” includes “any person suffering from a permanent or chronic physical or mental impairment which substantially limits one or more major life activities, such as caring for one’s self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, or working.” U.S. Note 4(a), Subchapter XVII, Chapter 98, HTSUS. Subheading 9817.00.96, HT

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 dharmendra.lilia@cbp.dhs.gov. 
Sincerely,
 (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division