Bauerhin Technologies Limited Partnership v. United States

Bauerhin Technologies Limited Partnership (Bauerhin) (plaintiff) imported cushioned inserts for child car seats filled with cotton and polyester known as baby pads. While the baby pads were imported separately from the car seats for which they were designed, the products were packaged together when sold to the ultimate consumer or otherwise sold as replacement parts. Bauerhin also imported canopies to be used with car seats. The United States Customs Service (customs) (defendant) classified the baby pads as non-cotton cushions under subheading 9404.90.20 of the Harmonized Tariff Schedule of the United States (HTSUS), with heading 9404 being applicable to articles of bedding and similar furnishing, including cushions. Customs classified the canopies as “other made up textile articles” under subheading 6307.90.94. Bauerhin challenged the classification, arguing that heading 9404 was limited to items having to do with sleeping or napping. Instead, because the principal use of baby pads was not sleep, Bauerhin argued that the baby pads should have been classified as seats and parts thereof under subheading 9401.91.10, which specifically covered parts of car seats. Bauerhin also argued that the canopies should have been categorized under heading 9401. The United States Court of International Trade agreed with customs’ classification of the baby pads but with Bauerhin’s classification of the canopies. Both parties cross-appealed.