Compact automatic-open travel umbrella with windproof fiberglass ribs and pongee canopy

GRI Reasoning

Step 1 – GRI 1: Heading Identification

The product is a compact automatic-open travel umbrella. Chapter 66 covers umbrellas and sun umbrellas. Heading 6601 explicitly covers "Umbrellas and sun umbrellas (including walking-stick umbrellas, garden umbrellas and similar umbrellas)." The product is unambiguously an umbrella; classification begins and ends in heading 6601 under GRI 1.

Step 2 – GRI 6: Subheading Selection

Within heading 6601, the verified HTS rows provide:

• 6601.10.00.00 – Garden or similar umbrellas (general rate: 6.5%). A compact travel umbrella is not a garden umbrella; this subheading is ruled out.
• 6601.91.00.00 – Other: Having a telescopic shaft (general rate: Free; Column 2 / "other" rate: 40%). A compact automatic-open travel umbrella is defined by its collapsible, multi-section (telescopic) shaft that retracts for portability. This is the hallmark feature of such umbrellas and aligns directly with the subheading language.

Alternative subheadings 6601.99.30 (other umbrellas, cover of man-made fibers) and 6601.99.90 (catch-all other) would only apply if the shaft were not telescopic. Because the compact travel umbrella's defining structural feature is its telescopic/collapsible shaft, 6601.91.00.00 is the correct 8-digit subheading under GRI 6.

Step 3 – Canopy Material (Pongee)

Pongee is a plain-woven fabric typically of polyester (a man-made fiber). This would be relevant to distinguish between 6601.99.30 and 6601.99.90 within the "Other" branch, but since the telescopic shaft places this product in 6601.91 rather than 6601.99, canopy material does not alter the subheading selection.

Step 4 – 10-Digit Statistical Suffix

The verified HTS rows provide the code only to 8 digits (6601.91.00.00 with trailing zeros already shown as the full statistical code in the evidence). The dossier recommends 6601.91.00.00 as the deepest level supported by the supplied evidence.

Step 5 – Duty Rate

• General (MFN) rate: Free (as shown in verified HTS row for 6601.91.00.00)
• Column 2 rate: 40%
• Section 301 / Chapter 99 overlay: No Chapter 99 subheading for umbrellas from China is present in the supplied evidence. This must be independently verified with a licensed broker or via CBP/USTR Section 301 lists, as it could impose a significant additional ad valorem duty on Chinese-origin goods.

Step 6 – Ruling Analogues

None of the three supplied CBP rulings (N342104, N298406, H100676) classify umbrellas or goods in Chapter 66. They address furniture (Chapter 94) and plastics (Chapter 39). No on-point umbrella ruling was supplied; accordingly, no ruling is cited as analogous precedent.

Step 7 – Commercial Context

At $4.20 declared unit value × 10,000 units = $42,000 annual import value. With a Free MFN rate, base duties are $0. However, any Section 301 additional duty (e.g., 7.5%–25%) on Chinese-origin umbrellas could represent $3,150–$10,500 annually and must be confirmed.

Conclusion

6601.91.00.00 is the recommended classification. Confidence is MEDIUM due to absence of an on-point ruling and unconfirmed Section 301 overlay.