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RE: The tariff classification of a wooden dresser prototype from Indonesia
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 N364803 September 24, 2026 CLA-2-98:OT:RR:NC:N5:433 CATEGORY: Classification TARIFF NO.: 9817.85.01 Scott Leonard Ballard Designs, Inc. 1670 Defoor Ave., NW Atlanta, GA 30318 RE: The tariff classification of a wooden dresser prototype from Indonesia Dear Mr. Leonard: In your letter dated September 2, 2026, you requested a tariff classification ruling. In lieu of samples, illustrative literature and a product description were provided. The “Grace 5-Drawer Tall Dresser” is a chest of drawers constructed of wood that will be imported to evaluate design, construction, functionality, manufacturing methods, finish, durability, hardware performance, packaging, and consumer acceptance before commercial production. Once the evaluation is complete, the article will be destroyed and not made available for retail sales or commercially distributed. The fully assembled dresser is constructed of engineered wood, solid mahogany, beech wood, and will have 5 slow-close drawers with knob pulls, pencil molding, tapered legs, stained mahogany drawer interiors, and anti-tip hardware. The dresser approximates 41 ½ inches long, 20 inches wide, and 55 ¾ inches tall. Information provided states, (1) the dresser will be labeled as a “Prototype not for resale” on the commercial invoice, (2) the dimensions, materials, and the construction are representative of potential future productions that will eventually become unique SKU numbers, and (3) if the physical dresser is not destroyed during testing, it will be labeled “Not for Resale” on the reverse so that photographs for marketing purposes may be taken. The ruling request seeks classification of the subject merchandise in subheading 9817.85.01 of the Harmonized Tariff Schedule of the United States, (HTSUS). Based on the information presented, the subject merchandise may qualify for duty free treatment as a prototype under subheading 9817.85.01, provided that all of the conditions delineated in U.S. Note 7, Chapter 98, Subchapter XVII, HTSUS are satisfied. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. The holding 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 P. Forkan Director National Commodity Specialist Division
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 P. Forkan Director National Commodity Specialist Division