Classification conclusion
A finished 150 × 200 × 6 cm coir-core mattress may fall in HTSUS 9404.29.9095. Review dimensions, USDA APHIS, CPSC flammability and origin-specific AD/CVD risk.
| Field | Conclusion |
|---|---|
| Proposed HTS code | 9404299095 — Other mattresses of other materials; candidate for the stated non-crib 6 cm configuration |
| Jurisdiction | United States |
| Tariff edition | HTSUS 2026 |
| Rules applied | GIR/GRI 1 and 6 |
| Confidence | High when the entered merchandise matches the stated facts |
| Condition | A finished 150 × 200 × 6 cm bed mattress with a cleaned, dried and compressed coconut-coir core enclosed in polyester ticking, without springs, cellular rubber or plastics, heating or cooling. |
Conditional U.S. classification conclusion
The product is a finished bed mattress with a cleaned, dried and compressed coconut-coir core enclosed in a textile ticking. It is not loose coir imported as raw material. If the mattress contains no innersprings, cellular rubber or plastics, heating or cooling system, and its stated dimensions are 150 × 200 × 6 cm, the leading 2026 U.S. candidate is HTSUS 9404.29.9095 — mattresses of other materials, other.
| Issue | Conditional conclusion |
|---|---|
| HTSUS | 9404.29.9095, subject to confirming the current statistical breakout and dimensions at entry |
| General duty | The current 9404.29.90 family generally carries 6% ad valorem; verify the live HTSUS on the entry date |
| Plant-health control | Do not assume an exemption solely because the article is finished; check USDA APHIS ACIR using origin and processing facts |
| Product safety | Mattresses generally require compliance with 16 CFR Parts 1632 and 1633 |
| Trade remedies | Mattress AD/CVD scope must be screened by origin, producer and exporter |
This is not a binding CBP ruling. The Importer of Record remains responsible for reasonable care, complete dimensions, origin, valuation and all additional duties.
Product facts that control the result
The opinion assumes a retail-ready mattress whose resilient support core is a consolidated sheet of natural coconut fibre, with a sewn or zippered polyester textile cover. The declaration file should confirm the composition by weight, core treatment, firmness, thickness, width and length, absence of springs and foam, and whether the mattress is intended for an adult bed, crib or toddler bed.
Marketing statements such as “pure coir” and “zero glue” are relevant evidence but are not substitutes for a bill of materials and manufacturing specification.
Why heading 9404 applies
Under GRI 1, heading 9404 expressly covers mattresses stuffed or internally fitted with any material, whether or not covered. A finished article having the objective form and use of a mattress is classified as the mattress, not as loose vegetable textile fibre.
CBP ruling N340071 confirms that heading 9404 is an eo nomine provision for mattresses and distinguishes the “other materials” branch from cellular rubber or plastics. Under GRI 6, the product falls outside 9404.21 if coconut coir, rather than cellular rubber or plastics, supplies the support core.
The ten-digit suffix is dimension-sensitive. The stated six-centimetre depth does not satisfy the reporting line for mattresses exceeding eight centimetres; the product is not assumed to be a crib or toddler-bed mattress. On those facts, 9404.29.9095 is the appropriate candidate. Recheck the live USITC HTS before filing because statistical suffixes and duty rates can change.
Duty, MPF, HMF and special tariffs
Budget the Column 1 general duty shown in the live HTSUS, plus Merchandise Processing Fee. Harbor Maintenance Fee may apply to ocean entries. Preferential treatment depends on qualifying origin and a valid program claim.
Section 301 is not determined from the product name alone. If the mattress is of Chinese origin, test the current Chapter 99 treatment against the exact eight-digit provision and effective exclusions. Section 232 is not ordinarily indicated for this finished mattress, but no special-tariff conclusion should be carried forward without an entry-date review.
Mattress AD/CVD risk
Mattresses are subject to significant U.S. antidumping and countervailing-duty activity. Scope language, not the HTS number by itself, controls. The written mattress scopes can reach products with cores made from foam, innersprings, other resilient filling, or combinations, and may cover mattresses imported independently or with furniture.
Before shipment, search the Department of Commerce ACCESS and AD/CVD resources by origin, producer and exporter. Do not conclude “not subject” merely because the coir core is unusual or the goods enter under 9404.29.9095. For a high-value or recurring program, obtain U.S. trade-counsel scope advice and consider a formal scope ruling.
CPSC flammability standards
The Consumer Product Safety Commission states that mattresses are generally subject to both:
- 16 CFR Part 1632, smoldering ignition resistance.
- 16 CFR Part 1633, open-flame performance for mattress sets.
The CPSC mattress guidance requires prototype testing, production and quality-assurance records, and permanent English labels containing specified manufacturer/importer, manufacturing date, model, prototype and compliance information. A general-use mattress also requires a General Certificate of Conformity (GCC) based on a reasonable testing program; CPSC publishes a mattress GCC example.
A “zero glue” statement does not waive flammability testing. Any substitution of ticking, coir density, barrier fabric, thread, tape edge or construction should be evaluated against the qualified prototype and recordkeeping rules.
USDA APHIS and coconut-coir processing
USDA APHIS regulates plants and plant products based on commodity, origin, processing and intended use. A finished mattress containing highly processed coir is materially different from loose coir used as growing medium, but the tariff classification does not itself create a plant-health exemption.
Use the APHIS Agricultural Commodity Import Requirements database with the actual country of origin and processing method. Keep evidence of cleaning, drying, heat or steam treatment, compression, absence of soil, seeds, husk fragments and live pests. If ACIR does not clearly address the finished configuration, request written APHIS guidance before loading.
Origin marking, textile description and claims
The article or its container must be marked with the correct country of origin under 19 U.S.C. §1304 and CBP rules unless a specific exception applies. The importer should separately review FTC textile-fibre identification and labeling rules for the textile ticking and any regulated claims.
Claims such as “organic,” “chemical free,” “antibacterial,” “hypoallergenic,” “non-toxic” or “zero formaldehyde” require reliable substantiation. A pesticide or antimicrobial claim can create additional EPA issues depending on the wording and treatment used.
Entry and compliance file
- Commercial invoice describing a finished coir-core mattress and complete dimensions.
- Packing list, bill of lading and customs bond information.
- Bill of materials, cross-section photographs and model specification.
- Coir cleaning, drying and treatment records; pest- and soil-free declaration.
- Origin analysis and country-of-origin marking artwork.
- HTS classification memorandum and current tariff printout.
- AD/CVD scope screening by country, producer and exporter.
- 16 CFR 1632/1633 prototype tests, quality records, permanent label and GCC.
- Claim substantiation and applicable textile-label records.
U.S. risk controls
The largest risks are treating loose or insufficiently processed coir as an automatically admissible finished product, choosing the wrong dimension-based suffix, importing before CPSC prototype qualification, and overlooking an AD/CVD order. The Importer of Record should issue written instructions to the broker and retain the classification and compliance file for audit.
Action conclusion
For a 150 × 200 × 6 cm, non-spring, non-foam finished coconut-coir mattress, HTSUS 9404.29.9095 is the leading candidate. Confirm dimensions and the current HTSUS, obtain APHIS treatment guidance where ACIR is unclear, complete CPSC flammability testing and GCC/labeling, and perform an origin-specific AD/CVD scope review before entry.
2026 U.S. customs and import-law review
Legal review date: September 5, 2026. The USITC online HTSUS identified 2026 Revision 18 on this review date. Rates and Chapter 99 measures can change during the year, so the legally operative schedule is the edition in effect on the entry date.
1. Quick legal conclusion
The proposed reporting number is 9404299095 for Other mattresses of other materials; candidate for the stated non-crib 6 cm configuration, but only for merchandise that matches this defined scope: A finished 150 × 200 × 6 cm bed mattress with a cleaned, dried and compressed coconut-coir core enclosed in polyester ticking, without springs, cellular rubber or plastics, heating or cooling. This is a fact-dependent classification opinion, not a CBP ruling and not a determination of admissibility, origin or AD/CVD scope.
2. Facts that must be verified before entry
- Exact width, length, depth and intended bed type
- Core composition, treatment, moisture, binders, foam, springs and ticking
- Origin, manufacturer, model, packaging and safety test reports
Also obtain the complete bill of materials, technical drawings, model numbers, operating manual, condition and configuration as imported, transaction chain, manufacturer/producer, country of origin of material inputs and intended U.S. use. A material difference requires a new analysis.
3. HTSUS analysis and controlling authority
- GRI 1 places a complete article having the objective identity of a mattress in heading 9404 rather than treating its coir core as loose vegetable fibre.
- GRI 6 selects the other-materials branch because the support core is coir and the stated product has no cellular rubber, plastics or springs.
The analysis must begin with GRI 1, the heading text and binding Section/Chapter Notes, then proceed to GRI 2–5 only if legally necessary and to GRI 6 for subheadings. U.S. Additional Rules of Interpretation and Additional U.S. Notes are controlling where applicable. WCO Explanatory Notes are persuasive interpretive material but are not U.S. statutory text. A CROSS ruling is binding only for the requester and merchandise covered by its facts; materially similar rulings may be persuasive. CIT and Federal Circuit decisions control within their jurisdiction.
Goods outside this opinion include:
- Loose coir, crib mattresses, foam or latex mattresses, spring mattresses, heated or cooled mattresses, mattress pads and separately imported covers require separate classification.
For recurring or high-value entries, request a prospective binding ruling from CBP under 19 CFR Part 177 and disclose all material facts. A ruling request is not a substitute for checking post-ruling HTSUS amendments or trade remedies.
4. Duty, fee and tax matrix
| Charge | Legal treatment for this article |
|---|---|
| HTSUS Column 1 General duty | Apply the rate printed beside 9404299095 in the HTSUS edition effective on the entry date. Any rate stated elsewhere in the article remains provisional until that check is completed. |
| Merchandise Processing Fee (MPF) | Formal entries generally incur 0.3464% of entered value, excluding duty, freight and insurance, subject for FY 2026 to the CBP minimum $33.58 and maximum $651.50; an applicable preference program can alter MPF treatment. |
| Harbor Maintenance Fee (HMF) | 0.125% of value when commercial cargo is unloaded from a vessel at a covered U.S. port; it ordinarily does not apply to air freight. See 26 U.S.C. 4461–4462 and 19 CFR 24.24. |
| Section 301 / other Chapter 99 duty | Determine from the exact 8-digit HTSUS provision, country of origin, effective date and any valid exclusion. Report the required Chapter 99 number; do not assume the base HTS rate is the total landed duty. |
| Section 232 | Check current Chapter 99 notes, product/derivative coverage, origin and any required steel/aluminum/copper content, melt-and-pour or smelt-and-cast data. It does not apply merely because the article contains some metal. |
| AD duty | Not determinable from an HTS number. The written scope of an AD order is dispositive; HTS references are for convenience. Review product, producer/exporter, origin and circumvention findings. Cash-deposit and final assessment rates can differ. |
| CVD duty | The same written-scope rule applies. Confirm the case-specific company or all-others cash-deposit rate and liquidation instructions in Commerce ACCESS and ACE. |
| Safeguard / quota | Check current Chapter 99, quota and safeguard measures as of entry. Product scope, origin, quantity and quota period control. |
| Federal excise tax | No product-specific federal excise tax is identified from the stated facts; confirm the intended use and the current Internal Revenue Code before entry. |
| State sales/use and other state taxes | These are not CBP customs duties. They depend on destination, importer nexus, later sale/use and state/local law and require a separate domestic-tax review. |
This table does not calculate landed cost. The importer must also determine customs value under 19 U.S.C. 1401a, including assists, packing, royalties/license fees, proceeds and related-party acceptability. A “first sale” claim requires a bona fide sale for export to the United States, arm's-length evidence and a complete transaction trail.
5. AD/CVD and evasion review
Mattresses are subject to multiple country-specific AD/CVD proceedings. Determine producer, exporter, origin, construction and whether the written scope covers the imported mattress; a heading 9404 number is only a convenience reference and is not dispositive.
The written scope description is dispositive; an HTSUS number in an order is only a convenience reference. If coverage is uncertain, obtain a Commerce scope ruling under 19 CFR 351.225 before relying on a non-covered position. Minor processing or assembly in a third country can trigger a circumvention analysis. False origin, undervaluation or evasion can lead to EAPA investigation under 19 U.S.C. 1517 and civil penalties under 19 U.S.C. 1592.
6. Partner Government Agency and product compliance
Mattresses generally require compliance with CPSC flammability standards in 16 CFR Parts 1632 and 1633, supported by required records and labeling. Natural coir and wood packaging should be screened for USDA/APHIS admissibility and treatment requirements.
PGA admissibility is independent of tariff classification. Transmit all required agency data and documents through ACE; a CBP release does not cure a violation of an FDA, CPSC, EPA, FCC, DOT, USDA or other agency rule.
7. Origin, marking and UFLPA
Determine nonpreferential origin under the substantial-transformation test and any product-specific rule; do not rely only on the shipping country, invoice origin or location of final packing. Mark the article and, when required, its container under 19 U.S.C. 1304 and 19 CFR Part 134, unless a documented exception applies. Section 301, AD/CVD, government procurement and a preference program may use distinct origin rules.
Under 19 U.S.C. 1307 and the UFLPA, goods mined, produced or manufactured wholly or in part in Xinjiang, or by an entity on the UFLPA Entity List, are subject to a rebuttable presumption of exclusion. Maintain supplier identity, production, payment, logistics and input-tracing evidence; a generic supplier declaration is not enough for a high-risk supply chain.
8. Minimum entry file
- CBP entry/cargo release data and Form 7501 record, customs bond, commercial invoice, packing list and bill of lading/air waybill.
- Purchase orders, payment records, Incoterms, assists/royalties analysis and related-party or first-sale valuation support.
- Product specifications, drawings, photographs, manuals, composition/BOM, model cross-reference and condition as imported.
- Signed classification memorandum applying the GRIs, legal notes, current HTSUS text and relevant rulings, plus rejected alternatives.
- Origin and marking analysis; producer/supplier affidavits and traceability records; Chapter 99 and exclusion support.
- AD/CVD scope search, producer/exporter case numbers and cash-deposit instructions, even when the conclusion is “not covered.”
- All PGA registrations, certificates, laboratory reports, licenses, notices and ACE data required for this product.
Keep entry and supporting records for the statutory period, generally five years, under 19 U.S.C. 1508 and 19 CFR Part 163.
9. Principal legal risks
- Declaring a 10-digit number from the trade name without proving the imported condition and legally relevant characteristics.
- Omitting a Chapter 99 number or calculating only the Column 1 rate.
- Treating an AD/CVD HTS cross-reference as dispositive instead of reading the written scope.
- Using shipping country as origin without a substantial-transformation and marking analysis.
- Filing before PGA admissibility, certificates, laboratory evidence or supply-chain traceability are complete.
An incorrect entry can produce redelivery, exclusion/seizure, duty reassessment, interest, loss of liquidation defenses and penalties. If past entries contain a material error, promptly evaluate a post-summary correction, protest, prior disclosure under 19 CFR 162.74 or other corrective procedure with U.S. customs counsel; the correct route depends on entry and liquidation status.
10. Pre-entry action checklist
1. Lock the specifications and imported configuration for the exact SKU. 2. Re-run classification against the current HTSUS and record GRI/Note reasoning. 3. Determine customs value, nonpreferential origin and marking. 4. Screen Chapter 99, Section 301/232, quota/safeguard and every potentially relevant AD/CVD scope. 5. Complete the product-specific PGA review and obtain supporting certificates before shipment. 6. Calculate landed duties and fees, then have the importer and licensed customs broker validate ACE reporting. 7. For unresolved or commercially material classification issues, obtain a CBP Part 177 ruling before importation.
Official legal sources
- United States International Trade Commission; HTSUS 2026: Harmonized Tariff Schedule of the United States
- U.S. Customs and Border Protection; N340071: Mattresses of other materials under heading 9404
- Consumer Product Safety Commission; 16 CFR Parts 1632 and 1633: Mattresses, mattress pads and mattress sets
- USITC — Current Harmonized Tariff Schedule of the United States
- CBP — User fee table: MPF rate and FY 2026 minimum/maximum
- CBP — Harbor Maintenance Fee
- CBP — ACE: filing customs and Partner Government Agency data
- USTR — Section 301 tariff actions and exclusion search
- BIS — Section 232 steel and aluminum measures
- Commerce — AD/CVD FAQs, scope and circumvention rules
- Commerce — ACCESS AD/CVD proceeding search
- CBP — UFLPA rebuttable presumption
- CPSC — Certificates and mandatory eFiling guidance
- FDA — Importing food products into the United States
- EPA — TSCA requirements for importing chemicals
- PHMSA — Lithium battery transportation requirements
- FCC — Equipment authorization
- eCFR — 19 CFR Part 177: administrative rulings
- eCFR — 19 CFR Part 134: country-of-origin marking
- eCFR — 19 CFR Part 163: recordkeeping
> Legal notice: This article provides general U.S. customs and trade-compliance information based on the stated facts as of September 5, 2026. It is not a CBP, Commerce or PGA ruling and is not legal advice for a specific transaction. Current HTSUS/Chapter 99 text, agency requirements and case-specific AD/CVD instructions must be rechecked at entry.
Editorial note
Prepared by the Global HS Code Checker Editorial Team for customs-classification, tariff and import-policy research. The correct code and applicable measures may change with the merchandise's actual characteristics, jurisdiction, entry date and supporting record. Verify the current tariff, governing measures and competent customs authority before filing an entry. A reviewer is identified only after a named expert has completed the review.
