CLA-2-83:OT:RR:NC:N1:121

Mr. Ping Lam
Sun Bright Industrial Corp.
4812 Temple City Blvd.
Temple City, CA 91780

RE: The tariff classification of mounting kits for exit devices from Malaysia, Singapore, Taiwan or China

Dear Mr. Lam:

In your letter dated November 15, 2010, you requested a tariff classification ruling. Pictures of the merchandise were submitted with this request.

The merchandise under consideration is mounting kits for exit devices for use on doors. Each mounting kit includes the following components: two pieces of part number 25-0470, the plastic top portion of the mounting kit’s end cap; two pieces of part number 23-0577, the aluminum alloy bottom portion of the mounting kit’s end cap; one piece of part number SY-AD009, an aluminum alloy profile having a cross section of 2.375 inches by 1.34 inches; and part number SY-AD010, an aluminum alloy profile having a cross section of 2 inches by 1.36 inches. Parts SY-AD009 and SY-AD010 are anodized in black, bronze or clear and may range in length from 22.5 inches to 46 inches long depending on the size of the door to which they will be affixed.

The applicable subheading for the exit device mounting kits will be 8302.41.6045, Harmonized Tariff Schedule of the United States (HTSUS), which provides for base metal mountings, fittings and similar articles…other mountings, fittings and similar articles, and parts thereof, suitable for buildings, other, of iron or steel, of aluminum or of zinc, suitable for interior and exterior doors (except garage, overhead or sliding doors), other. The rate of duty will be 3.9 percent ad valorem.

The mounting kits from China may be subject to antidumping duties or countervailing duties. Written decisions regarding the scope of AD/CVD orders are issued by the Import Administration in the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs and Border Protection. You can contact them at http://www.trade.gov/ia/ (click on "Contact Us"). For your information, you can view a list of current AD/CVD cases at the United States International Trade Commission website at http://www.usitc.gov (click on "Antidumping and countervailing duty investigations"), and you can search AD/CVD deposit and liquidation messages using the AD/CVD Search tool at http://www.cbp.gov (click on "Import" and "AD/CVD").

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/.

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 Barbara Kaiser at (646) 733-3024.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division