## Facts

- Importers brought in two textile products used with child automobile safety seats: cushioned seat inserts (“baby pads”) and canopies.
- The baby pads were stuffed textile inserts shaped to fit specific child safety seats, with sewn openings for restraining devices/safety belts; they were imported separately but sold with seats or as replacement items.
- The canopies were designed to fit over specific child safety seats; they were imported separately but sold as components of those seats.
- Customs classified the baby pads under HTSUS heading 9404 (cushions and similar stuffed furnishings) and the canopies under HTSUS heading 6307 (other made up textile articles).
- The Court of International Trade (CIT) upheld the baby-pad classification under heading 9404 but reclassified the canopies as parts of seats under HTSUS heading 9401.
- The importers appealed the baby-pad ruling; the United States cross-appealed the canopy ruling.

## Issues

1. Whether child-seat inserts, imported separately and shaped for specific child safety seats, are classifiable as “cushions and similar stuffed furnishings” under HTSUS heading 9404 or as “parts” of seats under heading 9401.
2. Whether canopies designed for child safety seats are classifiable under the residual textile provision in HTSUS heading 6307 or as “parts” of seats under HTSUS heading 9401.

## Decision

- The Federal Circuit affirmed the CIT’s judgment in full.
- The baby pads were properly classified under HTSUS heading 9404 as cushions or similar stuffed furnishings, not under heading 9401 as seat parts.
- The canopies were properly classified under HTSUS heading 9401 as parts of seats, not under heading 6307 as other made up textile articles.

## Legal Principles

- Tariff classification follows a two-step inquiry: (1) construe the relevant HTSUS provisions as a matter of law; (2) determine whether the merchandise falls within those provisions, which is also a legal determination when material facts are undisputed.
- HTSUS heading 9404 is not limited to sleep-related items; its text expressly includes “cushions” and similar stuffed furnishings.
- An article’s identity as a cushion/stuffed furnishing can control classification even if it is designed for use with a particular seat, especially where it is not a structural or necessary component of the seat.
- “Parts” classification under HTSUS heading 9401 turns on whether the item is dedicated solely or principally to the seat and is sufficiently connected to the seat’s function or use.
- Residual “basket” provisions such as HTSUS heading 6307 apply only when no more specific provision describes the merchandise; a specific parts provision prevails over a general residual textile heading when the item is identifiable as a seat part.

## Conclusion

The court held that child safety-seat inserts are classifiable as cushions under HTSUS heading 9404, while canopies specifically designed and sold for child safety seats are classifiable as seat parts under HTSUS heading 9401, rejecting Customs’ use of the residual textile heading 6307 for the canopies.


Bauerhin Techs. Ltd. P'ship v. United States, 110 F.3d 774 (Fed. Cir. 1997)