Tariff classification of high chair pads
Active· CBP ruling HQ 081593· Issued 1988-09-26
Ruling text
HQ 081593
September 26, 1988
CLA-2 CO:R:C:G 081593 SM
CATEGORY: Classification
TARIFF NO.: 6304.93.0000
Mr. John M. Bolte
BDP International, Inc.
815 World Trade Center
Baltimore, MD 21202
RE: Tariff classification of high chair pads
Dear Mr. Bolte:
Your letter of October 15, 1987, addressed to our New
York office, requests a tariff classification ruling on be-
half of Graco Children's Products for high chair pads to be
imported from Taiwan.
FACTS:
The sample high chair pad, "Item G," is marked "100
percent polyester." It measures approximately 21 by 25 inches
exclusive of the 1-1/4-inch ruffle at the top. This ruffle
has no function but enhances the appearance of the pad and
constitutes ornamentation for tariff purposes. The pad con-
sists of a woven printed front panel and a knit back, with a
thin layer of nonwoven man-made fiber batting in between. The
three layers are quilted together. An inverted "pocket" on
the upper back of the high chair pad slips over the back of a
chair. Four self-stick hook and loop fastener strips would
help hold the pad in place in a chair. Two slits would
accommodate a safety strap.
You state that an Import Specialist at the port of Bal-
timore has advised you informally that this merchandise would
be classified under item 367.6380, Tariff Schedules of the
United States Annotated (TSUSA), a provision for other fur-
nishings, not ornamented. You also state that authorities in
Taiwan have advised you that it would be classified under item
367.8980, TSUSA; however, there is no such tariff number.
ISSUE:
How are high chair pads of textile materials classified
under the TSUSA and the Harmonized Tariff Schedule of the
United States Annotated (HTSUSA)?
-2-
LAW AND ANALYSIS:
Subpart C, Part 5, Schedule 3, TSUSA, provides for fur-
nishings. Headnote 1 of Subpart C defines furnishings as fol-
lows:
the term 'furnishings' means . . . and furniture
slipcovers; and like furnishings; all the foregoing
of textile materials, and not specially provided
for.
Thus, to be classified as a furnishing, a textile article must
be one of the named articles or "like" one of those articles.
In our view the high chair pad is in the nature of a
furniture slipcover in that it slips over a chair which is al-
ready complete without it. Similar articles, such as infant
seat covers, have been so classified. See, for example, file
081847 of July 6, 1988.
HOLDING:
The high chair pad is classified under item 365.8980,
TSUSA, textile category 666, as other ornamented furnishings
of man-made fibers. The current rate of duty is 12.8 percent.
Under the HTSUSA, heading 6304 provides for other
furnishing articles. The high chair pad is classified under
subheading 6304.93.0000, textile category 666, a pro-
vision for other furnishings, not knitted or crocheted, of
synthetic fibers. (Synthetic fibers include polyester and
nylon.) The rate of duty is 10.6 percent. This classifica-
tion represents the present position of the Customs Service
under the HTSUSA. If there are changes before the effective
date of January 1, 1989, this advice may not continue to be
applicable.
Sincerely,
John Durant, Director
Commercial Rulings Division
6cc: Area Director, NY Seaport Area
cc: CITA
cc: Legal Reference Section
cc: NIS Richard Eyskens
cc: Phil Robins
Source: rulings.cbp.gov — ruling 081593, retrieved 2026-10-12T05:18:00Z, republished verbatim. This digest is informational; only CBP issues binding rulings.