&&This is a three step, portable staircase designed to allow pet dogs and cats to access furniture such as sofas and beds. The Cozy Pet 3 Steps is composed of a rigid cardboard core that is covered in a washable, removable cover made of a padded carpet-like polyester material on the steps and risers, a polyester material on the sides and a non-skid base. This product is fifteen inches high, supports animals up to 150 lbs, and features a carry handle.

&&Section 10 of the Customs Tariff directs that classification of imported goods shall be determined in accordance with the General Rules for the Interpretation of the Harmonized System. Section 11 of the Customs Tariff states that in interpreting the headings and subheadings, regard shall be had to the World Customs Organization's (WCO) Explanatory Notes to the Harmonized Commodity Description and Coding System.&&&&General Interpretative Rule 1 (GIR 1) directs that titles of Sections, Chapters and sub-Chapters are provided for ease of reference only. For legal purposes, classification shall be determined according to the terms of the heading and any relative Section and Chapter Notes. Similarly, General Interpretative Rule 6 (GIR 6) directs that classification shall be determined according to the terms of those subheadings and any related Subheading Notes.&&&&A proposed tariff classification number has not been provided in your submission; the tariff classification number as determined is found under the section titled “Decision”.&&&&Classification of the Cozy Pet 3 Steps as furniture of heading 94.03 was initially considered, however, the Explanatory Notes to this heading specifically exclude ladders and steps, instructing that “these are classified according to their constituent material (headings 44.21, 73.26, etc.)”. As this product is composed of two materials classified in different headings of the Tariff – the textile cover of heading 63.07 and the cardboard core of heading 48.23 – it will be classified in accordance with GIR 3(b), under the heading of the material that provides the product with its essential character. While the textile cover provides aesthetic appeal and enhanced stability (via the non-skid base) to the product, the cardboard core provides the product with its form, structure and weight-bearing ability. Information provided with your request also indicates that the cardboard core comprises 80% of the value of the product. Based on its role and value, it is the cardboard core that provides the essential character to the product. As such, the Cozy Pet 3 Steps is appropriately classified in heading 48.23, which covers other articles of paper pulp, paper, paperboard, cellulose wadding or webs of cellulose fibres.&&