N354111

N354111 October 20, 2025 CLA-2-94:OT:RR:NC:N5:433 CATEGORY: Classification TARIFF NO.: 9403.20.0086; 9903.01.24; 9903.81.91; 9903.01.25; 9903.88.03 Luke Kahnk Tank Holding Corp 6940 O Street, Suite 200 Lincoln, NE 68510 RE: The tariff classification of metal furniture from China Dear Mr. Kahnk: In your letter dated September 23, 2025, you requested a tariff classification ruling. In lieu of samples, illustrative literature, descriptions, and a manufacturing synopsis is provided for review. Item 1, the “Mat Cart Rack Kit,” is a floor standing steel tube metal frame rack. The rack will consist of 3 vertically upright post supports, 2-tiers of corrugated horizontal steel metal shelf decking, 1 non-corrugated steel metal base, and additional metal components that will provide structure, support, strength, and reinforcement when the cart is assembled and load bearing. The rack dimensions are 43 ¼” in length, 32 ½” in width, 59 ¾” in height, and has a load capacity of 1500 lbs. Item 2, the “Shuttle Sling Rack Cart Kit” is a floor standing steel tube metal frame rack. The rack will consist of 4 segmented bi-fold wire mesh panels that incorporate hinges. The hinges will allow the 4 segmented bi-fold wire mesh panels to swing upward and downward. As contents are added and the rack is filled, the wire mesh panels swing upward for increased storage capacity. The rack dimensions are 59 ½” in length, 28 ½” in width, 58 ¼” in height, and has a load capacity of 2500 lbs. Item 3, the “One-Rod Relay Rack Cart Kit” is a floor standing steel tube metal frame rack. The rack will consist of 2 segmented bi-fold wire mesh panels that incorporate hinges. The hinges will allow the 2 segmented bi-fold wire mesh panels to swing upward and downward. As contents are added and the cart is filled, the wire mesh panels swing upward for increased storage capacity. The 2 remaining wire mesh panels do not fold, extend an additional 18” in height, and incorporates a hanger rod that runs the length of the rack. The rack dimensions are 55” in length, 23 ¾” in width, 72 1/8” in height, and has a load capacity of 2500 lbs. In the condition at the time of U.S. importation, item 1, item 2, and item 3 will be unassembled, unequipped, and will include all hardware for assembly. Further, each cart will not include swivel casters. After U.S. importation, standard and upgraded swivel caster kits will be obtained from domestic suppliers. The binding ruling request seeks classification of the subject merchandise in 8716, which provides for “Trailers and semitrailers; other vehicles, not mechani cally propelled; parts thereof.” Although the Explanatory Notes (ENs) for 87.16 do include trailers and other vehicles capable of being propelled by hand, it is the opinion of this office that these racks do not fit into the type of hand propelled vehicles classified here. These racks are provided for elsewhere in the nomenclature. Alternatively, the binding ruling request seeks classification of the subject merchandise in subheadings 9403.20.0082, 9403.20.0086, 9403.99.9040; and 9403.99.9045 Harmonized Tariff Schedule of the United States, (HTSUS). The Harmonized Commodity Description and Coding System ENs constitute the official interpretation of the Harmonized System at the international level. The ENs to Chapter 94 of the HTS, for “Furniture,” states: “the term “furniture” means: Any “moveable” articles (not included under other more specific headings of the Nomenclature), which have the essential characteristic that they are constructed for placing on the floor or ground, and which are used, mainly with a utilitarian purpose, to equip private dwellings, hotels, theatres, cinemas, offices, churches, schools, cafes, restaurants, laboratories, hospitals dentists’ surgeries, etc., or ships, aircraft, railway coaches, motor vehicles, caravan-trailers or similar means of transport. (It should be noted that, for the purposes of this Chapter, articles are considered to be “movable” furniture even if they are designed for bolting, etc., to the floor, e.g., chairs for use on ships). Similar articles (seats, chairs, etc.,) for use in gardens, squares, promenades, etc., are also included in this category.” Further, the ENs to Chapter 94, heading 9403 of the HTS, provides “This heading covers furniture and parts thereof, not covered by the previous headings. It includes furniture for general use (e.g., cupboards, show cases, tables, telephone stands, writing desks, escritoires, book cases, and other shelved furniture (including single shelves presented with supports for fixing them to the wall), etc.), and also furniture for special uses.” Information provided conveys item 1, the “IMat Cart Rack Kit,” item 2, the “Shuttle Sling Cart Rack Kit,” and item 3, the “One-Rod Relay Cart Rack Kit” will be used to move floor mats and soiled linens to and from laundry facilities from clients such as grocery stores, kitchens, hotels, hospitals, and other institutions with heavy food traffic. In view of the given facts, the subject merchandise is within the construct of the Chapter 94 EN for furniture. EN I to General Rule of Interpretation (GRI) 2(a) provides: “the first part of Rule 2(a) extends the scope of any heading which refers to a particular article to cover not only the complete article but also that article incomplete or unfinished, provided that, as presented, it has the essential character of the complete or finished article.” EN V to GRI 2(a) provides: “the complete or finished articles presented unassembled or disassembled are to be classified in the same heading as the assembled article. When goods are presented, it is usually for reasons such as requirements or convenience of packing, handling or transport.” Further, Chapter 94 ENs provides: “articles of furniture presented disassembled or unassembled are to be treated as assembled articles of furniture, provided the parts are presented together.” Item 1, the “Mat Cart Rack Kit,” item 2, the “Shuttle Sling Cart Rack Kit,” and item 3, the “One-Rod Relay Cart Rack Kit” though incomplete and unassembled, are nevertheless dedicated components to identifiable articles of commerce, specifically, metal frame cart racks. For each kit, the cartons will contain the respective components along with assembly hardware. For each kit, standard and custom swivel casters will be the only missing component. For the convenience of packing, handling or transport, each carton contains the necessary components to assemble the complete kits. Each kit will be treated as a single assembled article of furniture. In this instance, as presented, item 1, item 2, and item 3 have the essential character of complete cart racks. The applicable subheading for the subject merchandise will be 9403.20.0086, HTSUS, which provides for “Other furniture and parts thereof: Other metal furniture: Other: Counters, lockers, racks, display cases, shelves, partitions and similar fixtures: Other.” The general rate of duty will be free. Trade Remedy: Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition to subheading 9403.20.0086 HTSUS, listed above. On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter 99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 percent upon the value of the steel content. At the time of entry, you must report 

Corp 6940 O Street, Suite 200 Lincoln, NE 68510 RE: The tariff classification of metal furniture from China Dear Mr. Kahnk: In your letter dated September 23, 2025, you requested a tariff classification ruling. In lieu of samples, illustrative literature, descriptions, and a manufacturing synopsis is provided for review. Item 1, the “Mat Cart Rack Kit,” is a floor standing steel tube metal frame rack. The rack will consist of 3 vertically upright post supports, 2-tiers of corrugated horizontal steel metal shelf decking, 1 non-corrugated steel metal base, and additional metal components that will provide structure, support, strength, and reinforcement when the cart is assembled and load bearing. The rack dimensions are 43 ¼” in length, 32 ½” in width, 59 ¾” in height, and has a load capacity of 1500 lbs. Item 2, the “Shuttle Sling Rack Cart Kit” is a floor standing steel tube metal frame rack. The rack will consist of 4 segmented bi-fold wire mesh panels that incorporate hinges. The hinges will allow the 4 segmented bi-fold wire mesh panels to swing upward and downward. As contents are added and the rack is filled, the wire mesh panels swing upward for increased storage capacity. The rack dimensions are 59 ½” in length, 28 ½” in width, 58 ¼” in height, and has a load capacity of 2500 lbs. Item 3, the “One-Rod Relay Rack Cart Kit” is a floor standing steel tube metal frame rack. The rack will consist of 2 segmented bi-fold wire mesh panels that incorporate hinges. The hinges will allow the 2 segmented bi-fold wire mesh panels to swing upward and downward. As contents are added and the cart is filled, the wire mesh panels swing upward for increased storage capacity. The 2 remaining wire mesh panels do not fold, extend an additional 18” in height, and incorporates a hanger rod that runs the length of the rack. The rack dimensions are 55” in length, 23 ¾” in width, 72 1/8” in height, and has a load capacity of 2500 lbs. 

In the condition at the time of U.S. importation,