Binding Ruling Letters NY N132069, NY N245061, and NY N246761, CBP classified child car seat cushions in heading 9401, HTSUS, specifically in subheading 9401.90.50, HTSUS, which provides for “[s]eats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: [p]arts: [o]ther: [o]ther”. CBP has reviewed the aforementioned rulings and determined the ruling letters to be in error. It is now CBP’s position that child car seat cushions are properly classified in heading 9404, HTSUS, specifically in subheading 9404.90.20, HTSUS, which provides for “[m]attress supports; articles of bedding and similar furnishing (for example, mattresses, quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed or internally fitted with any material or of cellular rubber or plastics, whether or not covered: [o]thers: [p]illows, cushions and similar furnishings: [o]thers”.
CBP analysis and conclusion are found in the Customs Bulletin for January 12, 2022 (Vol. 5, No. 1) beginning on Page 40.
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