Background

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.

Playing Cards

CBP is proposing to reclassify plastic-coated paper cards used to play various games as playing cards under HTSUS 9504.40.00 (duty-free) rather than as other games under HTSUS 9504.90.9080 (duty-free). Rulings NY N319955 and HQ 088829 would be revoked, and rulings NY N319421 and NY L88167 would be modified, to reflect this change.

CBP explains that the Harmonized System Committee’s stated intent behind the subheading provision for playing cards is to cover card games of all kinds, not just those played with a standard deck of four suits. In addition, it has been CBP’s practice to classify all types of playing cards under HTSUS 9504.40.00.

Pet Bowl Mats

CBP is proposing to reclassify 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 is also proposing to find that the country of origin of this product is China rather than Vietnam. Ruling NY N307920 would be modified 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.

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