OT:RR:CTF:EMAIN H348177 JRG
TARIFF NOS.: 8473.30.15; 9903.01.24; 9903.88.03
Craig Corato
JMC Global Technologies LLP
616 Henrietta Creek Rd., Suite 100
Roanoke, Texas 76262
RE: Modification of NY N346879; Tariff classification of a bezel assembly from China
Dear Mr. Corato:
This is in response to your request for reconsideration, dated May 13, 2025, of New York
Ruling Letter (NY) N346879, dated March 31, 2025. NY N346879 concerns the tariff
classification of a bezel assembly under the Harmonized Tariff Schedule of the United States
(HTSUS). The subject bezel assembly is described in NY N346879 as follows:
The merchandise under consideration is identified as the Bezel Assy, PN 8CW5K,
which is described as a bezel faceplate with locking key that is intended to be
installed on the front of a 2U server. The Bezel Assy is constructed of plastic, metal,
springs, and fasteners and is an accessory to data storage machines.
As correctly stated in NY N346879, the Bezel Assy, PN 8CW5K, is properly classified
under heading 8473, HTSUS, and specifically provided for under subheading 8473.30.51,
HTSUS, which covers, "Parts and accessories (other than covers, carrying cases and the like)
suitable for use solely or principally with machines of heading 8470 to 8472: . . . Parts and
accessories of the machines of heading 8471: Not incorporating a cathode-ray tube: . . .Other."
The general, column one rate of duty for goods of this provision is free.
As correctly stated in NY N346879, the subject merchandise is also subject U.S. note
20(u) to Subchapter III to Chapter 99, HTSUS, and therefore covered by heading 9903.01.24,
HTSUS, in addition to subheading 8473.30.51, HTSUS. Goods covered by this provision are
subject to an additional 20 percent ad valorem rate of duty.
Also as correctly stated in NY N346879, the subject merchandise is covered by U.S. note
20(f) to Chapter 99, HTSUS. As such, it is covered by heading 9903.88.03, HTSUS. Goods
covered by this provision are subject to an additional 25 percent ad valorem rate of duty.
In your reconsideration request, you indicate that the subject bezel assembly does not
contain any aluminum. As such, this ruling only concerns the potential applicability of U.S. note
19(k) to Subchapter III to Chapter 99, HTSUS. As stated in NY N346879, goods covered under
this provision are indeed classified under heading 9903.85.08, HTSUS, to the extent that such
goods have aluminum content. However, if the bezel assembly does not contain aluminum, as
you claim, you are not required to report heading 9903.85.08, HTSUS, in addition to subheading
8471.30.51, HTSUS.
Duty rates are provided for your convenience and are subject to change. The text of the
most recent HTSUS and the accompanying duty rates are provided on World Wide Web at
https://hts.usitc.gov/current.
Please note that 19 C.F.R. § 177.9(b)(1) provides that “[e]ach ruling letter is issued on the
assumption that all of the information furnished in connection with the ruling request and
incorporated in the ruling letter, either directly, by reference, or by implication, is accurate and
complete in every material respect. The application of a ruling letter by a [CBP] field office to the
transaction to which it is purported to relate is subject to the verification of the facts incorporated
in the ruling letter, a comparison of the transaction described therein to the actual transaction, and
the satisfaction of any conditions on which the ruling was based.”
NY N346879, dated March 31, 2025, is hereby MODIFIED to clarify the applicability of
U.S. note 19(k) to the subject merchandise.
This modification of treatment is not subject to the notice and comment provisions of 19
U.S.C. § 1625(c) because NY N346879 was in effect for less than 60 days.
Sincerely,
for Yuliya A. Gulis, Director
Commercial and Trade Facilitation Division
2
3