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Classification Changes Proposed for Framed Mirrors, Insulated Bags, Mineral Boards

Thursday, July 30, 2020
Sandler, Travis & Rosenberg Trade Report

The following proposed revocations and modifications of U.S. Customs and Border Protection rulings are included in the July 22, 2020, Customs Bulletin and Decisions. Comments on these proposed changes are due by Aug. 21.

For more information on how to seek or utilize classification and other rulings, please contact Deb Stern at (305) 894-1007.

Framed Mirrors

CBP is proposing to reclassify framed mirrors used a part of a modular closet storage and organization system as other furniture under HTSUS 9403.89.60 (duty-free) rather than as wooden furniture of a kind used in the bedroom under HTSUS 9403.50.9080 (duty-free). CBP explains that the glass surface of the mirror imparts its essential character, not the wooden frame. Ruling NY N304224 would be revoked to reflect this change.

Insulated Bags

CBP is proposing to reclassify insulated pizza, grocery, and food delivery bags as insulated food or beverage bags with outer surface of textile materials under HTSUS 4202.92.08 (7 percent duty) rather than as other made-up articles under HTSUS 6307.90.98 (7 percent duty) or as plastic articles for the conveyance or packing of goods under HTSUS 3923.29.00 (3 percent duty) or HTSUS 3923.10.90 (3 percent duty). CBP explains that these rulings were issued before a 2003 change to the language of heading 4202 to specifically include insulated food or beverage bags. Rulings HQ967177, NY N020627, NY N243289, NY N261656, and NY N260407 would be revoked to reflect this change.

Mineral Board Tiles

CBP is proposing to reclassify certain mineral board tiles designed for residential and commercial flooring and wall paneling as other articles of mineral substances under HTSUS 6815.99.4070 (duty-free) rather than as floor and wall tiles of artificial stone under HTSUS 6810.19.1400 (9 percent duty). CBP explains that it has long held that artificial stone must be comprised of natural rock uniformly agglomerated with a binder, whereas in the item at issue the polymer binder is agglomerated with mineral rather than stone. Ruling NY N287603 would be revoked to reflect this change.

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