The following proposed revocations of U.S. Customs and Border Protection rulings are included in the Aug. 7, 2024, Customs Bulletin and Decisions. Comments on these proposed changes are due by Sept. 7.
For more information on how to seek or utilize classification and other rulings, please contact attorney Deb Stern at (305) 894-1007 or via email.
Portable Toilets
CBP is proposing to reclassify child-sized portable toilets as plastic sanitary ware under HTSUS 3922.90.00 (6.3 percent duty) rather than as plastic lavatory seats and covers under HTSUS 3922.20.00 (6.3 percent duty). Ruling NY N319574 would be revoked to reflect this change.
The products at issue consist of a portable toilet seat, composed entirely of plastic components, intended for use by children. They include a hollow plastic base shaped like a toilet bowl onto which the user will sit. There is also a separate plastic pan that slides in and out of the base to allow for easy cleanup. Some have a removable plastic cover shaped like a toilet seat that can be used independent of the base on a regular toilet.
CBP explains that these items are miniature replica toilets, designed to help children become familiar with the ritual of relieving themselves into a toilet, and therefore are not merely lavatory seats and covers, which only provide comfort for the user while using a toilet.
Titanium Billets
CBP is proposing to reclassify forged titanium billets as other titanium articles under HTSUS 8108.90.60 (15 percent duty) rather than as unwrought titanium under HTSUS 8108.20.00 (15 percent duty). Ruling HQ H027436 would be revoked to reflect this change.
The product at issue is imported in billet form and is thereafter to be melted down for use in the manufacture of recreational equipment. The chemical analysis of the product is stated to be 90 percent titanium, six percent aluminum, and four percent vanadium by weight.
CBP explains that forged products are wrought, not unwrought, regardless of their stage of production.
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