Mr. Rick Dumas
UPS Supply Chain Solutions
One UPS Way
Champlain, NY 12919

RE: The tariff classification of a Drywall Aluminum Pole Sander from China

Dear Mr. Dumas:

In your letter dated December 27, 2011, on behalf of A Richard Tools, you requested a tariff classification ruling on three products including a Drywall Aluminum Pole Sander (item number 18310), a Professional Sponge Sander (item number 18270) and a Professional Sponge Sander (item number 18271). Item numbers 18270 and 18271 were sent to our U.S. Customs and Border Protection Laboratory for analysis. These two products will be addressed under ruling number N199021. The Drywall Aluminum Pole Sander (item number 18310) is the subject of this ruling. A sample of the subject aluminum pole sander was submitted for our review. Your sample will be returned as requested.

The merchandise under consideration is described as a 9 3/8 inch by 3 3/8 inch female-end aluminum pole sander for an extension pole. The sander in question features a rubber pad adhered to the bottom of the sander, and nickel plated steel mounting clips for attaching the sandpaper on the top of the sander. The sander has a universal joint with a standard female thread which allows for 360 degree rotation. You indicate that this universal joint helps to eliminate flipping of the sander while in use.

The applicable subheading for the Drywall Aluminum Pole Sander (item number 18310) will be 7616.99.5090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of aluminum, other…other. The rate of duty will be 2.5 percent ad valorem.

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

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Ann Taub at 646-733-3018.


Thomas J. Russo
National Commodity Specialist Division