Tariff Classification Advance Ruling
“Coleman Cooler Cushion, P/N 702-200”


Mr. Greg Friedman
Sunbeam Corporation (Canada) Limited
20B Hereford Street
Brampton, ON  L6Y 0M1

Date of issuance of ruling: March 10, 2016

This is in response to your request for an advance ruling on the tariff classification of the "Coleman Cooler Cushion, P/N 702-200".  This product is exported by The Coleman Company, 2111 East 37th Street North, Wichita, KS, 67219, USA.

TRS Number: 273843
Classification Number: 9404.90.90.29
Effective Date: March 10, 2016

Product Description

The "Coleman Cooler Cushion, P/N 702-200" is designed to provide convenient seating possibilities. It measures 17.5 x 20 x 3 inches and attaches to the cooler with buckle hoop-and-loop fastening straps.

The cover is a white UV resistant vinyl and the inside fill is polyurethane foam.  The "Coleman" logo is printed on the front side in blue. This model is compatible with the Coleman 150 Qt. marine Cooler with Split Lid and the Coleman 200 Qt. UV Marine Cooler. It is imported and sold separately.

Analysis and Justification

Heading 94.04 provides for: "mattress supports; articles of bedding and similar furnishing (for example, mattresses, quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed or internally fitted with any material or of cellular rubber or plastics, whether or not covered".

The Coleman Cooler Cushion, P/N 702-200 is an article designed to be placed on a hard surface (in this case a Coleman Cooler) for sitting upon, and meets the technical terms of heading 94.04, as a similar furnishing to an article of bedding that is covered in vinyl, and internally fitted with cellular plastic.


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 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.

The "Coleman Cooler Cushion, P/N 702-200" is classified under tariff classification 9404.90.90.29 by application of GIR 1 of the Harmonized System.

Legislative/Administrative References

This ruling has been issued under paragraph 43.1(1)(c) of the Customs Act and will be honoured by the Canada Border Services Agency (CBSA) for future importations of the goods specified, provided the material facts and circumstances remain as originally presented; all conditions in the ruling have been met; the ruling has not been modified, revoked, revised, or cancelled; and the Customs Tariff legislation has not changed. Should there be a change in the material facts or circumstances pertaining to the goods, you must notify the CBSA as soon as possible. You may request that the advance ruling be modified or revoked as of the date of the change.

Importers should quote the advance ruling number at the time of importation in either the description field of the B3 entry document or on the Canada Customs Invoice. Exporters or producers should quote the advance ruling number on the Certificate of Origin or commercial invoice accompanying the goods.

Should you disagree with this advance ruling, you may file a dispute notice under subsection 60(2) of the Customs Act within 90 days of the date of issuance. Please see the procedures outlined in Appendix C of the CBSA's Memorandum D11-11-3, Advance Rulings for Tariff Classification.

This advance ruling is considered reason to believe for the purposes of section 32.2 of the Customs Act and the CBSA's Administrative Monetary Penalty System, described in Memorandum D22-1-1.

All Memoranda referenced in this letter may be accessed on the CBSA website.

Consent to the Public Release of the Advance Ruling

As per your consent statement, we will release this advance ruling to the public, in both official languages, in accordance with the procedures described in Memorandum D11-11-3. The ruling will be published on the CBSA website in 30 days.

CBSA Contact

Mark Grant
Manager, Tariff Policy Unit 'B'
Trade Policy Division
Headquarters, Ottawa

File Number


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