In the Feb. 21, 2024, Customs Bulletin and Decisions, U.S. Customs and Border Protection is reclassifying the following products, effective with respect to goods entered or withdrawn from warehouse for consumption on or after April 22.

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

Pet Bowl Mats

CBP is reclassifying a pet bowl mat as a made-up article under HTSUS 6307.90.98 (7 percent duty) rather than as a textile floor covering under HTSUS 5705.00.2030 (3.3 percent duty). CBP has also determined that the country of origin of this product is China rather than Vietnam. Ruling HQ H325602 will modify ruling NY N307920 to reflect these changes.

The product at issue is a knitted floor covering consisting of three layers laminated together: a printed, knit pile face fabric of 100 percent polyester followed by a layer of foam and a 100 percent polyester knit backing fabric with polyvinyl chloride dots applied 3/8” apart from one another on one side to create a non-skid backing for the mat. The mat measures 10 x 20 inches and is finished along the four edges with an overlock stitch. The mat is folded and a cardboard sleeve is placed over it.

CBP explains that while the mat’s textile material is the exposed surface of the mat when in use, the mat is thin and flimsy and thus does not have the capacity to provide the durability and safety of a floor covering.

Cancer Treatments

CBP is issuing ruling HQ H330926 to modify ruling NY N319324 and hold that a transducer array is not eligible to be classified as an article for the permanently or chronically physically or mentally handicapped under HTSUS 9817.00.96 (duty-free). CBP’s primary classification of this product as an electric transducer under HTSUS 8543.70.45 (2.6 percent duty) remains unchanged.

The item at issue is composed of multiple interconnected electrical transducers designed to be adhered directly to the head or other area where an individual has been diagnosed with cancer. While connected to the electrical field generator within the system, the transducer array creates an alternating field that attracts and repels charged proteins during cancer cell division. The transducers do not electrically stimulate nerves or muscles, and they do not heat tissue.

CBP states that while cancer can cause chronic pain and substantial limitations to an individual’s life activities, it does not constitute a permanent or chronic physical or mental impairment. Instead, disabilities resulting from cancer fit within the definition of “acute or transient disabilities” and are thus specifically excluded from HTSUS 9817.00.96.

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