H346389

H346389 October 28, 2025 OT:RR:CTF:EMAIN H346389 TPB CATEGORY: Classification TARIFF NO.: 6307.90.98; 8708.29.51 Center Director U.S. Customs and Border Protection Apparel, Footwear and Textiles Center of Excellence and Expertise 555 Battery Street San Francisco, CA 94111 Attn: JP Vogan, Supervisory Import Specialist; S. Pereyra, Import Specialist Re: Protest and Application for Further Review No. 2704-25-171943; Classification of certain vehicle storage systems Dear Center Director: The following is our decision as to Protest and Application for Further Review No. 2704-25-171943, which was filed by counsel on behalf of their client, Westside Research, Inc. (Westside / Protestant). The protest pertains to the classification of three types of merchandise understood to be storage systems for use in vehicles, under the Harmonized Tariff Schedule of the United States (HTSUS). FACTS: The protest covers the following products stated to be storage systems for vehicles: the Westside Stored Energy Cargo Accessory (SECA) system, the Westside XG Gama Storage System, and the Westside XG Rail Station System. The invoice provided to U.S. Customs and Border Protection (CBP) describes the goods as camping organizers, various styles of camping organizer bags, and camping handle (two styles). At liquidation, CBP classified all three products in heading 4202, HTSUS, and specifically under subheading 4202.92.91, which provides for, in pertinent part, other containers and cases of heading 4202, “[w]ith outer surface of sheeting of plastic or of textile materials: Other: Other: With outer surface of textile materials, of man-made fibers (except jewelry boxes of a kind normally sold at retail with their contents).” Westside protested this action and provided additional information. Protestant claims that the SECA and XG Gama Systems are properly classified in subheading 8708.99.81, HTSUS, which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Other: Other,” and the Westside Rail Station System is properly classified in subheading 6307.90.98, HTSUS, which provides for “Other made up articles, including dress patterns: Other: Other: Other: Other.” The Westside Stored Energy Cargo Accessory (SECA) System is composed of polyester thread, a polyester shell and liner, steel springs, molded polypropylene, nylon and polyester webbing, and Velcro® straps. Protestant states that the SECA System is primarily designed to enhance or replace removable panels on the load floor of all-terrain vehicles and SUVs. Protestant further claims that this product is designed specifically for certain vehicles and will be permanently secured in place as a package option. The Westside XG Gama System is composed of polyester thread, nylon webbing, nylon buckles, nylon zippers, molded polypropylene internal frames, nylon and polyester webbing and Velcro, carbon steel external frames, and aluminum mounting brackets. Protestant states that the XG Gama System is primarily designed to be used with specific all-terrain vehicles that lack a trunk. Protestant further states that this product permanently bolts to the exterior rollbar of such all-terrain vehicles. It is designed to be attached to the outside of a vehicle during harsh weather conditions. The Westside XG Rail Station System is a textile backseat organizer designed to be used with certain all-terrain vehicles. It contains two textile mounting panels with headrest clips and elastic straps, four textile storage bags with backside clips, and one utility clip with a carabiner. The mounting panels are attached to the headrest posts via the headrest clips and secured using the elastic straps and C clips. Once attached, the storage bags can be clipped into the various apertures located on the mounting panel and secured via Velcro strips. Protestant states that the mounting platform permanently secures to the back of the vehicle seats. ISSUE: Whether the subject vehicle storage systems are classified as other containers and cases, other made up articles, or other parts and accessories of motor vehicles. LAW AND ANALYSIS: Initially, we note that the matters presently before us may be protested under 19 C.F.R. § 174.11(b)(2) (CBP administrative decisions that are “subject to protest” include “[t]he classification and rate and amount of duties chargeable”). This Protest is timely, as it is being submitted within 180 days of liquidation of all entries pursuant to § 174.12(e)(1). 2 Further, Protestant claims that this Protest also satisfies the eligibility criteria for further review under 19 C.F.R. § 174.24(a) because CBP’s decision to liquidate the subject merchandise under HTSUS heading 4202 is inconsistent with previous rulings by CBP on similar merchandise. Merchandise imported into the United States is classified under the HTSUS. Tariff classification is governed by the principles set forth in the General Rules of Interpretation (“GRIs”) and, in the absence of special language or context which requires otherwise, by the Additional U.S. Rules of Interpretation. The GRIs and the Additional U.S. Rules of Interpretation are part of the HTSUS and are to be considered statutory provisions of law for all purposes. GRI 1 requires that classification be determined first 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 heading and legal notes do not otherwise require, the remaining GRIs 2 through 6 may then be applied in order. Under GRI 6, the classification of goods in the subheadings of a heading is determined according to the terms of those subheadings and any related subheading notes and, mutatis mutandis, to GRIs 1 through 5. The Harmonized Commodity Description and Coding System Explanatory Notes (ENs), constitute the official interpretation of the Harmonized System at the international level. While neither legally binding nor dispositive, the ENs provide a commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of the headings. It is CBP’s practice to follow, whenever possible, the terms of the ENs when interpreting the HTSUS. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989). The HTSUS headings under consideration are as follows: 4202 Trunks, suitcases, vanity cases, attaché cases, briefcases, school satchels, spectacle cases, binocular cases, camera cases, musical instrument cases, gun cases, holsters and similar containers; traveling bags, insulated food or beverage bags, toiletry bags, knapsacks and backpacks, handbags, shopping bags, wallets, purses, map cases, cigarette cases, tobacco pouches, tool bags, sports bags, bottle cases, jewelry boxes, powder cases, cutlery cases and similar containers, of leather or of composition leather, of sheeting of plastics, of textile materials, of vulcanized fiber or of paperboard, or wholly or mainly covered with such materials or with paper 6307 Other made up articles 1, including dress patterns 8708 Parts and accessories of the motor vehicles of headings 8701 to 8705 1 See Note 7 to Section XI for a definition of “made up” for the purposes of that section. 3 Additionally, Note 3 to Section XVII states: References in chapters 86 to 88 to “parts” or “accessories” do not apply to parts or accessories which are not suitable for use solely or principally with the articles of those chapters. A part or accessory which answers to a description in two or more of the headings of those chapters is to be classified under that heading which corresponds to the principal use of that part or accessory. Westside XG Rail Station System As an initial matter, the Protest record does not contain any information regarding the textile composition of this system. However, based on a visual examination of the photographs provided in the Protest

Initially, we note that the matters presently before us may be protested under 19 C.F.R. § 174.11(b)(2) (CBP administrative decisions that are “subject to protest” include “[t]he classification and rate and amount of duties chargeable”). This Protest is timely, as it is being submitted within 180 days of liquidation of all entries pursuant to § 174.12(e)(1). 2 

Further, Protestant claims that this Protest also satisfies the eligibility criteria for further review under 19 C.F.R. § 174.24(a) because CBP’s decision to liquidate the subject merchandise under HTSUS heading 4202 is inconsistent with previous rulings by CBP on similar merchandise. Merchandise imported into the United States is classified under the HTSUS. Tariff classification is governed by the principles set forth in the General Rules of Interpretation (“GRIs”) and, in the absence of special language or context which requires otherwise, by the Additional U.S. Rules of Interpretation. The GRIs and the Additional U.S. Rules of Interpretation are part of the HTSUS and are to be considered statutory provisions of law for all purposes. GRI 1 requires that classification be determined first 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 heading and legal notes do not otherwise require, the remaining GRIs 2 through 6 may then be applied in order. Under GRI 6, the classification of goods in the subheadings of a heading is determined according to the terms of those subheadings and any related subheading notes and, mutatis mutandis, to GRIs 1 through 5. The Harmonized Commodity Description and Coding System Explanatory Notes (ENs), constitute the official interpretation of the Harmonized System at the international level. While neither legally binding nor dispositive, the ENs provide a commentary on the scope of each heading of the HTSUS and are generally indicative o