Double-wall vacuum insulated stainless steel water bottle, 32 ounce, with leakproof screw lid
Country of origin for this scenario: China.
Recommended HTS code
9617.00.10.00
Having a capacity not exceeding 1 liter
HIGH confidence. Heading 9617 is the specific provision for vacuum vessels and controls over the general household-articles heading 7323 under GRI 1 / Note 2 specificity principles. Two directly on-point 2026 CBP rulings (N353266 and N356922) classify double-wall vacuum-insulated stainless-steel water bottles/tumblers of ≤1 liter capacity to 9617.00.1000. HQ H303684 (2021) formally revoked prior 7323 classifications for the same type of article and confirmed 9617.00.10 as correct. The subject bottle is 32 oz (≈0.946 L), which falls within 'not exceeding 1 liter,' matching the subheading. The product is stainless steel with no predominant plastic content (distinguishing N338561). No open verification questions remain on the heading or subheading.
Classification analysis generated on July 17, 2026 from the current Harmonized Tariff Schedule and published CBP rulings, for the product description shown — our analysis, not legal advice.
How the classification was reached
GRI Reasoning
Step 1 – GRI 1: Heading Identification
Two headings are plausible:
- 7323.93.00 – Table, kitchen or other household articles of stainless steel (general rate 2%).
- 9617.00 – Vacuum flasks and other vacuum vessels, complete (general rates 7.2%–6.9% depending on capacity).
Chapter 73 Note and GRI 1 specificity: Heading 9617 specifically names "vacuum flasks and other vacuum vessels." The product is literally a double-wall vacuum-insulated vessel. Where a more specific heading exists, it prevails over a general household-articles heading under GRI 1 and the principle that specific descriptions take precedence over general ones.
Step 2 – CBP Precedent
HQ H303684 (July 7, 2021) is controlling authority: CBP headquarters formally *revoked* multiple NY rulings that had classified insulated stainless-steel beverage containers under 7323 and held that such articles are properly classified under 9617.00.10, HTSUS. The revocation covered tumblers, travel mugs, and cylindrical bottles — all functionally identical to the subject merchandise.
N353266 (January 28, 2026): CBP classified a vacuum-insulated stainless-steel water bottle available in 18, 24, and 32 oz sizes (item #ORC21501, with plastic screw-top lid) to 9617.00.1000 (≤1 liter). The facts are nearly identical to the subject product.
N356922 (January 28, 2026): CBP classified a double-wall vacuum-sealed stainless-steel tumbler (28 oz, ≤1 liter) to 9617.00.1000. Also directly on-point.
Step 3 – Capacity / Subheading Selection
32 U.S. fluid ounces = approximately 0.946 liters, which does not exceed 1 liter. Therefore the correct subheading is 9617.00.10.00 ("Having a capacity not exceeding 1 liter"), general duty rate 7.2%.
Step 4 – Elimination of Alternatives
- 7323.93.00.80: Overridden by the more specific heading 9617 per GRI 1 and HQ H303684 revocation.
- 3924.10.4000: Applicable only where plastic components impart essential character (N338561 involved 85.3% plastic, removable stainless interior). The subject article is stainless steel throughout; plastic lid is ancillary. Not applicable.
- 7323.93.00.60: Same reasoning as 7323.93.00.80; excluded by HQ H303684.
Step 5 – China Section 301 / Chapter 99 Overlay
The verified HTS row for 9617.00.10.00 carries no 9903.88.15 footnote in the supplied data (unlike some 7323 subheadings). However, both N353266 and N356922 explicitly note that Chapter 99 additional duties (including IEEPA-based tariffs) may apply and must be verified at time of entry. The importer should confirm current Section 301 / IEEPA applicability with a licensed broker at time of filing, as those overlays change frequently and are not definitively resolved by the ruling text alone.
Step 6 – Duty Estimate (based on supplied rates)
| Component | Rate |
|---|---|
| General (MFN) duty | 7.2% |
| Column 2 (non-MFN) | 55.5% |
| Section 301 / Chapter 99 overlay | Flag for broker verification |
At declared unit value of $4.70 × 18,000 units = $84,600 annual import value. MFN duty at 7.2% = ~$6,091 before any Section 301 overlay.
Cited CBP rulings
Every ruling below was fetched from CBP’s public CROSS database and verified to exist before this page was published. Links go to the official ruling text.
What it classified: Vacuum-insulated stainless-steel water bottle (item #ORC21501), available in 18, 24, and 32 oz, with black plastic screw-top lid, from China
Why it’s analogous: Virtually identical merchandise: double-wall vacuum-insulated stainless-steel water bottle with plastic screw-top lid in the same size range (including 32 oz), from China. CBP classified to 9617.00.1000 (≤1 liter). Facts and classification are directly on-point for the subject product.
What it classified: Double-wall vacuum-sealed stainless-steel tumbler (28 oz, model #SSCC-01) with aluminum lid, from China
Why it’s analogous: Same constructional principle (double-wall, vacuum-insulated stainless steel, ≤1 liter capacity). CBP laboratory confirmed vacuum insulation with no filler material. Classified to 9617.00.1000. Supports 9617 heading for the subject bottle.
What it classified: Insulated stainless-steel beverage containers (tumblers, travel mugs, cylindrical bottles) previously classified under 7323
Why it’s analogous: CBP Headquarters ruling that formally revoked prior NY rulings classifying vacuum-insulated stainless-steel beverage containers under 7323, holding that heading 9617 is the correct classification. Establishes the controlling legal principle that 9617 prevails over 7323 for vacuum-insulated stainless-steel beverage vessels.
What it classified: CoolCore insulated water bottle (85.3% plastic, 14.7% stainless steel, non-vacuum, double-wall, 11 oz) from China
Why it’s analogous: Distinguished: classified to 3924.10.4000 because the article was predominantly plastic (by weight) with no vacuum insulation and the plastic components imparted essential character under GRI 3(b). The subject bottle is stainless steel with true vacuum insulation, making 3924 inapplicable.
What the duty looks like
Duty math shown for illustrative declared values — $4.70 per unit at 18,000 units per year is our assumption for this explainer, not a measurement of anyone's imports. Your numbers will differ.
- Base duty rate (column 1, general)
- 7.2%
- Annual declared value at the illustrative numbers
- $84,600
- Base duty per year (illustrative)
- $6,091
- With chapter-99 overlays below (illustrative)
- $6,091
Alternatives considered
The full candidate set from the fetched tariff rows — including rows that would carry a higher duty. Shown so the reasoning is checkable, not to offer a rate menu.
| Code | Description | General rate | Note |
|---|---|---|---|
| 7323.93.00.80 | Of stainless steel | 2% | Table, kitchen or other household articles of stainless steel – 'Other.' General rate 2%. Was the historically common classification for insulated stainless-steel water bottles, but HQ H303684 (2021) revoked prior rulings placing vacuum-insulated containers here and established 9617 as controlling. Not recommended. |
| 3924.10.40.00 | Other | 3.4% | Tableware and kitchenware of plastics – Other. General rate 3.4%. Applicable only where plastic components impart essential character under GRI 3(b) (see N338561). The subject product is stainless-steel construction with vacuum insulation; plastic lid is ancillary. Not applicable. |
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