The following proposed revocations or modifications of U.S. Customs and Border Protection classification rulings are included in the Sept. 13, 2023, Customs Bulletin and Decisions. Comments on these proposed changes are due by Oct. 13.

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.

Click here for more information on ST&R’s upcoming classification webinars.

Car Cleaner

CBP is proposing to reclassify a 3-in-1 car cleaner as a motor vehicle accessory under HTSUS 8708.99.81 (2.5 percent duty) rather than as a brush or squeegee under HTSUS 9603.90.8050 (2.8 percent duty). Ruling HQ 952654 would be revoked to reflect this change.

The product at issue consists of a plastic handle and three interchangeable components: a plastic ice scraper, a foam squeegee with rubber blade, and a bristle brush. Each component may be separately secured to the handle and may be detached by pressing the handle clip.

CBP explains that this item is a motor vehicle accessory because it contributes to the effectiveness and affects the operations of motor vehicles of headings 8701 to 8705 by enabling the removal of ice or snow from their windows, lights, and other parts for better visibility while driving.

CBP also clarifies that this product is not excluded from classification under heading 8708 by Note 2(l) to Section XVII because that note only excludes items that are classified in their entirety under heading 9603, whereas in this case only part of the item is so classified.

Car Bumper Parts

CBP is proposing to reclassify bumper energy absorbers, bumper extensions, and bumper reinforcements as bumper parts under HTSUS 8708.10.60 (2.5 percent duty) rather than as other motor vehicle parts under HTSUS 8708.29.5060 (2.5 percent duty). Ruling NY N302213 would be modified to reflect this change.

The subject items include bumper energy absorbers, which are constructed of either foam or plastic and are designed to absorb impact in case of a collision while effectively protecting other components; bumper extensions, which are placed on the driver’s and passenger’s sides of the vehicle’s front and rear bumpers; and bumper reinforcements, which are made of aluminum, steel, or plastic and are designed to reinforce the bumper assembly by fortifying and shielding the bumper from severe damage.

CBP explains that these items absorb impact and provide rigidity and protection to the bumper, functions that are integral to the function of the bumper, and are thus properly classified as parts.


CBP is proposing to reclassify a plastic playmat as other printed matter under HTSUS 4911.99.8000 (duty-free) rather than as a plastic household article under HTSUS 3924.90.1050 (3.3 percent duty) and a printed playmat as a plastic floor covering under HTSUS 3918.90.1000 (5.3 percent duty) rather than as other printed matter under HTSUS 4911.99.8000 (duty-free). Rulings NY N091575 and NY N213371 would be revoked to reflect this change.

Both playmats are made of polyvinyl chloride foam plastic material. The plastic playmat has a top surface decorated with animation characters, whereas the printed playmat is reversible and both sides are printed with illustrations that depict letters, numbers, and objects.

With respect to the first playmat, CBP states that the printed animation characters form the essential nature and use of the item, which is therefore classified as printed matter. With respect to the second playmat, CBP explains that because it is imported in rolls it is classifiable in heading 3918 and excepted from chapter 49 even if printed with motifs, characters, or pictorial representations that are not merely subsidiary to the primary use of the goods.

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