Seats Convertible into Beds, Non-Wooden (Excluding Garden Seats and Camping Equipment)

The classification hinges on the article's design and primary function as a seat that converts to a sleeping surface. A futon with a non-wooden frame that functions as a sofa in its upright position and a bed when laid flat fits squarely in 9401.49. A daybed designed primarily for reclining or sleeping, with only incidental seating use, may instead be classified as a bed under heading 9403. Importers should retain product specifications and marketing materials to document the intended primary use.

Cambodia's growth as a supplier reflects both competitive labor costs and its position outside the scope of antidumping and countervailing duty orders that have targeted Chinese and, in some cases, Vietnamese furniture. Importers sourcing from Cambodia should nonetheless conduct origin verification to ensure that goods are genuinely manufactured there and not transshipped from countries subject to trade remedies, as CBP has increased enforcement of transshipment in the furniture sector.