N364096

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364096 September 2, 2026 CLA-2-94:OT:RR:NC:N5:433 CATEGORY: Classification; Origin TARIFF NO.: 9403.60.8093 Ritchie Basco C.H. Robinson Worldwide Canada Ltd. 1001 Blvd. Robert Bourassa, Suite 200 Montreal, QC H3B 4L4 Canada RE: The tariff classification and country of origin of wooden furniture. Dear Ms. Basco: In your letter dated August 6, 2026, you requested a tariff classification and country of origin ruling on behalf of Conglom Inc. In lieu of samples, illustrative literature and product descriptions were provided for review. Item 1, the “Laundry Cabinet Kit (SKU QL114),” is a storage cabinet, utility sink, two-handle pullout faucet, and strainer kit. The cabinet is constructed from particleboard, medium density fiberboard (MDF), and the cabinet’s exterior is finished with painted melamine. The sink is constructed of Acrylonitrile Butadiene Styrene (ABS) and is 14.5" deep. The two-handle pullout faucet and the strainer are constructed of stainless steel. The overall product dimensions are approximately 24.24" in width, 33.85" in height, and 21.45" in length. Upon importation into the United States, the kit will be packaged in a single carton and intended for residential laundry and utility purposes. Item 2, the “Laundry Cabinet Kit (SKU QL113),” is a storage cabinet, utility sink, single lever pulldown faucet, and strainer kit. The cabinet is constructed from particleboard, MDF, and the cabinet’s exterior is finished with painted melamine. The sink is constructed of stainless steel and is 9.5" deep. The single lever pulldown faucet and the strainer are also constructed of stainless steel. The overall product dimensions are approximately 24.17" in width, 33.5" in height, and 21.34" in length. Upon importation into the United States, the kit will be packaged in a single carton and intended for residential laundry and utility purposes. The ruling request seeks classification of item 1 and item 2 in subheading 9403.60.8093, Harmonized Tariff Schedule of the United States (HTSUS). Further, for item 1, the ruling request outlines a sourcing operation wherein the ABS sink, faucet, and the strainer will be sourced in China. For item 2, the ruling request outlines a sourcing operation wherein the stainless-steel sink, faucet, and the strainer will be sourced in China. The material components will be shipped and exported to Vietnam. In Vietnam, for item 1 and item 2, the cabinet raw material components will be locally sourced. The manufacturing operations undertaken in Vietnam for the cabinet involves (1) wood cutting of the particleboard and the MDF panels, (2) edge banding of the panels, (3) drilling of the panels, (4) assembly of the cabinet doors to the frame, and (5) painting of the cabinet doors and the frame. For item 1 and item 2, in Vietnam, the Chinese ABS sink, stainless steel sink, faucets, and the strainers will not undergo a manufacturing operation that results in a physical change such as die cutting, grinding, riveting, threading, hole punching, welding, soldering, fusing, machining, knurling, or crimping. In Vietnam, the Chinese origin components will be unpacked and repackaged with a specific Vietnamese cabinet. In Vietnam, the laundry cabinet kits will be inspected, packaged, and then exported to the U.S. The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitutes the official interpretation of the Harmonized System at the international level. The ENs to Chapter 94 of the Harmonized Tariff Schedule (HTS), for “Furniture,” states “the term ‘furniture’ means: (A) 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.” The ENs to Chapter 94, heading 9403 of the HTS, states “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.” Heading 9403 item (1) includes furniture for “Private dwellings, hotels, etc., such as: cabinets, linen chests, bread chests, log chests; chests of drawers, tallboys; pedestals, plant stands; dressing-tables; pedestal tables; wardrobes, linen presses; hall stands, umbrella stands; sideboards, dressers, cupboards; foodsafes; bedside tables; beds (including wardrobe beds, campbeds, folding beds, cots, etc.); needlework tables; stools and foot-stools (whether or not rocking) designed to rest the feet, fire screens; draughtscreens; pedestal ashtrays; music cabinets, music stands or desks; playpens; serving trolleys (whether or not fitted with a hot plate).” The laundry cabinet kits are within the construct of Chapter 94 and heading 9403 item (1); the unequipped wooden cabinets are general use articles of furniture. Further, the laundry cabinet kits (a) consists of at least two different articles which are, prima facie, classifiable in different headings (cabinets, faucets, sinks, strainers); (b) consists of products or articles put together to meet a particular need or carry out a specific activity (storage, organization); and (c) are put up in a manner suitable for sale directly to end users without repacking, therefore, the subject merchandise will be considered a set for customs purposes. Additionally, the cabinet components are the indispensable attribute that strongly marks or serves to distinguish the structure, core or condition of each article. The essential character of each laundry cabinet kit, as a whole, is imparted by the wooden furniture cabinet components. The applicable subheading for item 1 and item 2 will be 9403.60.8093, HTSUS, which provides for “Other furniture and parts thereof: Other wooden furniture: Other: Other: Other.” The general rate of duty will be free. Country of Origin: When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). The sinks, faucets, and the strainers from China are manufactured with a pre-determined end use prior to importation into Vietnam. The post-importation operations that occur in Vietnam involves unpacking and repacking of the individual Chinese components with a specific model of the Vietnamese manufactured cabinet. The unpacking and repacking of the Chinese components do not change the basic nature of the 

is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). The sinks, faucets, and the strainers from China are manufactured with a pre-determined end use prior to importation into Vietnam. The post-importation operations that occur in Vietnam involves unpacking and repacking of the individual Chinese components with a specific model of the Vietnamese manufactured cabinet. The unpacking and repacking of the Chinese components do not change the basic nature of the articles. The packaging into retail cartons in Vietnam does not result in a substantial transformation of the foreign origin Chinese components. There is no new name, character or use as the components retain their identities as Chinese origin sinks, faucets, and strainers. In view of these facts, for item 1 and item 2, the countries of origin for the purposes of applying current trade remedies will be China (the country of origin for the plastic sink, metal sink, metal faucets, and the metal strainers) and Vietnam (the country of origin of the wooden cabinets). AD/CVD Applicability: The merchandise in question may be subject to antidumping duties and countervailing duties (AD/CVD). The stainless-steel sink components may be subject to A-570-983 and C-570-984 from China. Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and Compliance office in the International Trade Administration of the Department of Commerce and are separate from tariff classification and origin rulings issued by C