Tariff Classification Advance Ruling
Dogit Puppy Training Pads


Ms. Pam Smith
Rolf C. Hagen inc.
20500, Trans-Canada Highway
Baie d'Urfé, QC H9X 0A2

Date of ruling:

This is in response to a request submitted on your behalf by Kuehne & Nagel for an advance ruling on the tariff classification of Dogit Puppy Training Pads. This product is manufactured by/exported from Silk Beauty Ltd, Ho Mein Town, Chang Hwa County, Taiwan.

TRS Number: 277024
Classification Number: 4818.90.00.00
Effective Date:

Product Description

The submitted products are quilted training pads for dogs. They are offered in different sizes ranging from 45cm x 33cm to 71cm x 86 cm. They are made of a thin layer of non-woven fabric, paper (cellulose) tissue, an absorbent core of cellulose fibres and superabsorbent polymer (SAP), and a polyethylene bottom layer. The pads effectively absorb moisture, keeping paws dry and preventing damage to floors.

Analysis and Justification

The training pads are composite goods and are to be classified according to the principles of GIR 3.

Heading 48.18 provides for, in part, household, sanitary or hospital articles of paper pulp, paper, cellulose wadding or webs of cellulose fibers. As the paper (cellulose) portion represents approximately 50 to 56% of the goods, it is that material which gives that article its essential character.


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 (WCO) 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 and, provided such headings or Notes do not otherwise require, according to the other GIRs. 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 Dogit Puppy Training Pads are classified under tariff classification number 4818.90.00.00 of the Canadian Customs Tariff in accordance with General Interpretative Rule 3(b) 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 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 D-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.

CBSA Contact

Aveluy Ramsay
A/Manager, Tariff Policy Unit B
Trade Policy Division
Headquarters, Ottawa

File Number


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