CLA-2-39:OT:RR:NC:N4:421
Mr. Ole Skaaning
Ken Hamanaka Co., Inc.
5777 West Century Blvd.
Suite 760
Los Angeles, CA 90045
RE: The tariff classification of French door components from China
Dear Mr. Skaaning:
In your letter dated October 5, 2010, on behalf of Global Products, LLC, you requested a tariff classification ruling.
You intend to import two components of a French door assembly. Photographs and diagrams were provided with your letter. The first component consists of the two door leaves or door panels which comprise the main element of the complete French door. The leaves are composed of polyvinyl chloride (PVC) plastic that is reinforced with steel. The door leaves are imported without the central glass panels, which will be added after importation. The second component consists of the pre-assembled T-astragal intended to seal the opening between the two panels of the door. The astragal is made of extruded aluminum and plastic and includes the hardware for assembly. The door leaves and the astragal will be packaged separately. The other components of the French door, i.e., the door frame and the glass panels for the door leaves, will be imported separately and packaged with the door leaves and astragal after importation. You did not supply any details about the door frame or glass panel components and you are not requesting a classification ruling on those components at this time.
The applicable subheading for the PVC door leaves/door panels will be 3925.20.0010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for builders’ ware of plastics, not elsewhere specified or included: doors, windows and their frames and thresholds for doors…doors and door frames. The rate of duty will be 5.3 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 http://www.usitc.gov/tata/hts/.
Your inquiry does not provide enough information for us to give a classification ruling on the aluminum astragals. Your request for a classification ruling should include sufficiently detailed information on the astragal so that we can determine the exact form in which it is imported. If submission of a sample is impractical, and if there is not a smaller illustrative model available for examination, then provide photographs showing different views of the product, including a picture of the complete astragal. Please clarify the function of the complete astragal, how it operates and if it is permanently attached to one of the doors after assembly. If the astragal is imported as more than one component or in a knocked down condition, provide a photograph of each separate component. Include a list showing each component and label each component in the illustration so that the component can be matched up with the picture. You have provided pictures of ten parts of the astragal, including the security flip lock, slide bolt length adjustment and EZ mount end block. Please annotate the illustration requested above with the location of each of these ten parts. If there are other parts of the astragal that you have not identified, list them and annotate their location as well. Identify which components of the astragal are made of aluminum and which are made of plastics. Please provide the chemistry of the astragal. If it is an alloy, then provide the specification to which it is made.
When this information is available, you may wish to consider resubmission of your request. If you decide to resubmit your request, please prepare a new request letter and include all of the material that we have returned to you, including a copy of this ruling.
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 Joan Mazzola at (646) 733-3023. If you have questions regarding the information needed for classification of the astragal, contact NIS Mary Ellen Laker at (646) 733-3020.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division