H341208

H341208 June 25, 2025 OT:RR:CTF:FTM H341208 BJK CATEGORY: Classification, Origin, and USMCA Eligibility TARIFF NO.: 3926.90.99 Mr. Stephen Lawson TAG Hardware 19072 26 Avenue Surrey, British Columbia V3Z 3V7 Canada RE: Tariff Classification, Country of Origin, and USMCA Eligibility of a Jewelry Organizer Tray and Drawer Organizer Kit Dear Mr. Lawson: This letter is in response to the request submitted by TAG Hardware, (“TAG” or “Requestor”), dated April 28, 2024, for a binding ruling regarding the tariff classification, country of origin, and eligibility for preferential tariff treatment under the United States Mexico Canada Agreement (“USMCA”) of a jewelry organizer tray and drawer organizer kit. The request concerns five items, of which the subject jewelry organizer tray and drawer organizer kit are identified as “Item 1” and “Item 3,” respectively. The National Commodity Specialist Division (“NCSD”) addressed the remaining three items in two separate rulings. Item 2, a decorative drawer liner, and Item 4, a drawer divider rails with liner kit, were the subject of New York Ruling Letter (“NY”) N340542, dated July 2, 2024. Item 5, a drawer divider and bracket kit, was the subject of NY N339814, dated May 22, 2024. Copies of each of these rulings are available on the Customs Rulings Online Search System (“CROSS”). The request concerning the subject jewelry organizer tray and drawer organizer kit was forwarded to our office by the NCSD. The NCSD also forwarded the samples of the jewelry tray and organizer kit that were submitted for review. In arriving at our determination set forth below, we also considered supplemental information submitted via e-mail by Mr. Ian Povey on behalf of TAG. FACTS: In its ruling request, the Requestor describes the jewelry organizer tray as follows: The product in question is a jewelry organizer tray designed to hold and organize a variety of jewelry items. The product is used inside a standard dresser or closet drawer. It comprises of a large PVC plastic extrusion, u- shaped profile and a medium-sized u-shaped profile, both manufactured in Canada. Both profiles are wrapped in Canada with a decorative PVC fabric. The PVC fabric is purchased on 55’ wide rolls, that is made in China. The jewelry organizer tray also contains 2 plastic injection molded earring holders, which are manufactured in Canada. Attached to the medium-sized u-shaped profile is a fabric wrapped foam ring-holder, which is made in China. As described above, the jewelry organizer tray consists of five pieces: one large u-shaped profile, which is a polyvinyl chloride (“PVC”) plastic extrusion covered with an imitation leather (PVC) fabric; one medium u-shaped profile, which is also a PVC plastic extrusion covered with the same imitation leather (PVC) fabric as the large u-shaped profile; two earring trays, which are molded plastic with shallow grooves for holding earrings (not covered with any type of fabric); and a ring holder, which is a molded foam covered in polyester fabric and glued to a paper base, that is inset into the medium u-shaped profile. The Requestor states that the jewelry organizer tray is manufactured in Canada and China. Specifically, the large and medium u-shaped profile plastic extrusions are produced in Canada and the imitation leather (PVC) fabric used to wrap the large and medium u-shaped profiles is produced in China. The large and medium u-shaped profiles are wrapped and glued with the imitation leather (PVC) fabric in Canada. The earring trays are produced in Canada via a plastic injection process, by which a plastic resin is injected into a custom-built metal mold, which is also built in Canada. The ring holder, consisting of the molded foam covered in polyester fabric and glued to a paper base, is produced entirely in China. The jewelry organizer tray, consisting of the pieces described above, is then packaged together in Canada and imported into the United States as one complete product. With respect to the drawer organizer kit, the Requestor describes it as follows: The item in question is a drawer organizer kit for storing jewelry, fashion accessories (such as belts and ties) and eyewear. The kit consists of three items: the jewelry organizer tray, the drawer liner, and an accessory tray. The jewelry organizer tray and the accessory tray are designed to sit on top of the drawer liner and slide back and forth within the drawer, to create customizable spaces for the home-[owners’] jewelry. The two trays and the liner will be packaged together and presented at the time of import as a [drawer] organizer kit. 2 The drawer organizer kit consists of three separate items: one jewelry organizer tray; one drawer liner, which was the subject of NY N340542, dated July 2, 2024; and an accessory tray. The jewelry organizer tray composition and manufacturing process is detailed above. In NY N340542, CBP described the drawer liner as follows: The first item under consideration is a drawer liner intended to be used for lining drawers in a closet drawer or dresser. The liners are composed wholly of polyester woven fabric laminated to a layer of cellular PVC on one side. The PVC layer is stamped with a pattern and cured with heat to give it a faux leather look. [T]he textile layer is brushed to help with adhesion. CBP classified the drawer liner under subheading 5903.10.20, of the Harmonized Tariff Schedule of the United States (“HTSUS”), as a “Textile fabric impregnated, coated, covered or laminated with plastics, other than those of heading 5902: With poly(vinyl chloride): Of man-made fibers: Other.” In NY N340542, CBP determined that the country of origin for the drawer liner was China and CBP outlined the manufacturing process as follows: The fabric is manufactured and laminated to the PVC in China; the PVC fabric is imported to Canada in 55-inch rolls along with rolls of double sided adhesive tape from China; the PVC fabric rolls are cut in Canada to specific widths and re- rolled; the double-sided adhesive tape is applied to the fabric rolls in Canada, and the tape laminated rolls are cut and packaged in Canada. Finally, the Requestor describes the accessory tray as comprised of a large, plastic extruded u-shaped profile and two small plastic u-shaped profiles. All three of the profiles, the one large u-shaped profile and two small u-shaped profiles, are wrapped in the same imitation leather (PVC) fabric that covers the jewelry tray and comprises the drawer liner. The Requestor states that the large u-shaped profile and two small u-shaped profiles are plastic extrusions produced in Canada. The PVC fabric, as mentioned above, is produced in China. The large u-shaped profile and two small u-shaped profiles are wrapped with the PVC fabric in Canada. ISSUES: What is the tariff classification of the jewelry organizer tray and drawer organizer kit? What is the country of origin of the jewelry organizer tray and drawer organizer kit? Whether the jewelry organizer tray and drawer organizer kit are eligible for preferential tariff treatment under the USMCA. LAW AND ANALYSIS: Classification decisions under the HTSUS are made in accordance with the General Rules of Interpretation (“GRIs”). GRI 1 provides that the classification of goods shall be determined 3 according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may then be applied in order. GRI 3 provides, in pertinent part, that: [w]hen, by application of rule 2(b) or for any other reason, goods are, prima facie, classifiable under two or more headings, classification shall be effected as follows: (a) The heading which provides the most specific description shall be preferred to headings providing a more general description. However, when two or more headings each refer to par

Classification decisions under the HTSUS are made in accordance with the General Rules of Interpretation (“GRIs”). GRI 1 provides that the classification of goods shall be determined 3 

according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may then be applied in order. GRI 3 provides, in pertinent part, that: [w]hen, by application of rule 2(b) or for any other reason, goods are, prima facie, classifiable under two or more headings, classification shall be effected as follows: (a) The heading which provides the most specific description shall be preferred to headings providing a more general description. However, when two or more headings each refer to part only of the materials or substances contained in mixed or composite goods or to part only of the items in a set put up for retail sale, those headings are to be regarded as equally specific in relation to those goods, even if one of them gives a more complete or precise description of the goods. (b) Mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale, which cannot be classified by reference to 3(a), shall be classified as if they consisted of the material or component which gives them their essential character, insofar as this criterion is applicable. . . . . The 2025 HTSUS provisions under consideration are as follows: 3924 Tableware, kitchenware, other household articles and hygienic or toilet articles, of plastics: 3924.90 Other: 3924.90.56 Other: * * * 3926 Other articles of plastics and articles of other materials of headings 3901 to 3914: 3926.90 Other: 3926.90.99 Other: * * * 4 

4202 Trunks, suitcases, vanity cases, attache cases, briefcases, school satchels, spectacle cases, binocular cases, camera ca