Background

The following proposed revocations of U.S. Customs and Border Protection classification rulings are included in the May 27, 2026, Customs Bulletin and Decisions. Comments on these proposed changes are due by June 26.

For more information on how to seek or utilize classification and other rulings, please contact STR.

Tubing Frame

CBP is proposing to reclassify a frame of a mechanic’s creeper as a seat under HTSUS 9401.71.0011 (duty-free) rather than as a vehicle part under HTSUS 8716.90.5060 (3.1 percent duty). Ruling NY N068156 would be revoked to reflect this change.

The product at issue is square metal tubing that is cut, drilled, bent, and welded into the frame of a mechanic’s creeper, which is used to roll underneath the chassis of a vehicle. The frame is cleaned, degreased, and powder painted and has four plastic plugs installed into pre-cut holes into which caster wheels will be mounted after importation, along with any other additional components necessary to complete a finished creeper.

CBP states that a creeper is not a non-mechanically propelled vehicle, as it is not used to transport goods or people, so the frame cannot be classified as a vehicle part. Instead, the creeper meets the definition of furniture and is akin to a seat, despite the fact that the user lies down to use it, and the frame is a part of it.

Battle Ropes

CBP is proposing to reclassify certain battle ropes as accessories of exercise equipment under HTSUS 9506.91.00 (4.6 percent duty) rather than as ropes under HTSUS 5609.00.3000 (4.5 percent duty). Rulings NY N340713 and NY N265390 would be revoked to reflect this change.

The products at issue are textile or polypropylene ropes designed to be anchored on a post and used for physical strength training at a gym or fitness facility. The ends of some of the ropes are wrapped with eight inches of polyvinyl chloride and secured with an aluminum collar, while the ends of others have plastic, heat-molded aglets.

In its original rulings CBP said there was nothing that distinguished these items from any other general-purpose ropes. However, CBP now identifies the plastic ends, which ensure a secure hold during a workout, as indicative of the ropes being specifically designed for physical strength training. CBP also finds that other factors weigh in favor of this determination, including the expectation of the ultimate purchaser and the channels of trade, and that the ropes are similar to other articles listed in Explanatory Note 95.06.

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