Stainless Steel Insulated Water Bottle (500 ml), US Import: HTSUS 9617.00.10.00, Medium-High Confidence
Interpretation: I assumed the bottle is double-walled with a vacuum between the walls (the usual meaning of "insulated" for steel bottles), a 500 ml capacity, and no stated country of origin. If it is only foam-insulated or non-vacuum, the answer changes (see the last column of the table). This is a recommendation to confirm with a licensed customs broker or CBP, not a binding classification. Tariff data accessed 5 October 2026.
Classification table
| Product | HS code (6-digit) | National tariff line | Description of line | General duty rate | Extra duties noted | Supporting ruling (link) | Confidence | What would change the code |
|---|---|---|---|---|---|---|---|---|
| Stainless steel insulated water bottle, 500 ml, drinkware | 9617.00 | 9617.00.10.00 | Vacuum flasks and other vacuum vessels, complete; parts thereof other than glass inners: Having a capacity not exceeding 1 liter | 7.2% (unit: No.) | China origin only: Section 301 "forced labor" duty, heading 9903.05.31, +12.5%; no Section 232 line found for 9617; AD/CVD unchecked (see below) | NY N321985 (3 Dec 2021); HQ H303684 (7 Jul 2021) | Medium-High (rated Medium on the SOP scale only because the ruling is on 17 oz bottles, not this exact article; see Notes) | No vacuum between the walls (foam or air only) would move it to 7323.93.00 (stainless household articles, 2% general rate). Capacity over 1 liter would move it to 9617.00.30 or .40. |
Why 9617 and not 7323
The deciding question is whether a vacuum-insulated steel bottle without a separate outer case is a "vacuum flask ... complete with cases" (heading 9617) or a steel household article (heading 7323). CBP settled this in HQ H303684. It revoked four earlier New York rulings that had put such bottles in 7323 and held that double-walled stainless containers with a partial vacuum between the walls fall in 9617.00.10 under GRI 1 and 6. CBP's reasoning has three parts:
- Case requirement: the legal text does not say the "case" must be separate from the outer wall, and the steel outer shell counts as a case.
- Explanatory Note: the heading 9617 note was revised in 2017 to include double-walled stainless steel vacuum insulated thermal flasks without a protective outer case.
- Section note: Section XV Note 1(m) excludes Chapter 96 goods from Chapters 72 to 83, so a good that fits 9617 cannot go in 7323.
A later New York ruling applied this to a near match. NY N321985 classified two double-walled, vacuum-insulated stainless bottles of 17 ounces (the ruling states 17 ounces, roughly the size of a 500 ml bottle by my own conversion) with no outer casing in 9617.00.1000, at a stated 7.2% ad valorem rate. That is the closest match found to a 500 ml bottle. The official CROSS page for N321985 returned only page furniture when I fetched it, so I read both rulings on CustomsMobile, a third-party mirror; I could not check them against rulings.cbp.gov.
Duty and extra measures
- General rate: the official HTS shows 7.2% for 9617.00.10.00, with "Free" for listed FTA partners (including A, AU, BH, CL, CO, D, E, IL, JO, KR, MA, OM, P, PA, PE, S, SG). The comparison line 7323.93.00 is 2% general, so the classification choice matters for cost.
- Section 301 forced-labor duty (China origin): the HTS heading 9903.05.31 reads the duty in the applicable subheading + 12.5%. A law-firm summary puts the effective date at 24 July 2026, with China among the economies paying 12.5%. Two commercial calculators show a 19.7% total for 9617.00.10.00 from China, built from the 7.2% base plus 12.5%, with one stacked measure. The Dentons alert says the new 301 duty does not apply to goods already covered by Section 232. I treat the calculators as secondary evidence and did not confirm the heading-level scope in USTR's notice.
- Legacy Section 301 China lists: the calculators show no legacy-list measure for this line, but I did not open the USTR list annexes. Treat this cell as secondary-source only.
- Section 232 (steel): the CBP guidance of 5 June 2026 lists the affected Chapter 1 to 97 lines in an attachment. I decoded that attachment (it is linked from the bulletin, a Word file): it contains 7323.93.00 among derivative steel articles but no 9617 line. On that list, 9617.00.10.00 is therefore not a Section 232 steel derivative. The same list would reach the rival code 7323.93.00, which is another reason the 9617 call carries a real cost difference. I read only this June 2026 list; later amendments are unchecked.
- IEEPA: the Supreme Court held on 20 February 2026 that IEEPA does not authorize tariffs, so I list no IEEPA duty.
- AD/CVD: unchecked. I did not query Commerce's or ITC's order lists, and the web search I ran surfaced no order on insulated drinkware, so I make no claim either way; confirm before entry.
Notes (rows that are not clean)
- Ruling match: neither ruling is on a 500 ml bottle with your exact features. NY N321985 is the closest (17 oz, vacuum-insulated, stainless, no outer casing); HQ H303684 is the binding reasoning. Both are from 2021, so I rate the row Medium-High. I did not search for rulings on copper-lined or triple-wall variants.
- Facts I assumed: vacuum insulation, stainless steel body, capacity 500 ml, with lid. Ask the factory whether the walls are vacuum-sealed or foam-filled. The lid alone, if imported separately, would fall under the parts line 9617.00.60.00 at 7.2%.
- Origin: every extra-duty finding depends on country of origin, which the request did not give.
Do next
- Confirm with the supplier that the walls are vacuum-sealed and the capacity is 500 ml.
- Confirm country of origin and check Section 301 and Section 232 treatment for that origin on the entry date.
- Re-read the current HTSUS and Chapter 99 on the entry date, because these rates changed repeatedly in 2026.
- If volume is large, request a binding ruling from CBP (I did not file one).
- Have a licensed customs broker confirm the line before filing.
Coverage: hts.usitc.gov and the CBP CSMS notice were reached. The official CROSS page returned no ruling text, so rulings were read on CustomsMobile. USTR list annexes and Commerce's AD/CVD order list were not opened.
Sources
- USITC HTS, heading 9617.00 (accessed 5 Oct 2026)
- USITC HTS, 7323.93.00 (accessed 5 Oct 2026)
- USITC HTS, 9903.05.31 Section 301 forced-labor heading (accessed 5 Oct 2026)
- CBP HQ H303684, 7 July 2021 (CustomsMobile copy)
- CBP NY N321985, 3 December 2021 (CustomsMobile copy)
- CBP CSMS 68855869, Section 232 guidance, 5 June 2026 (with attached HTS list)
- Dentons client alert, US tariff snapshot, 10 August 2026
- Wove, HTS 9617.00.10.00 duty page
- TariffsAPI, HTS 9617.00.10.00 page (synced 5 Oct 2026)