CLA-2-73:OT:RR:NC:1:117

Steven A. Clark
Vice President
Vinyl Fences Inc.
294 Durham Road
Dover, NH 03820

RE: The tariff classification of steel post adapters, rail adapters and rail connectors from India

Dear Mr. Clark:

In your letter dated January 10, 2011 you requested a tariff classification ruling.

The products you intend to import are described as galvanized steel post adapters, rail adapters and rail connectors for use in pergolas. The post adapters slide over the round steel posts of the pergola to allow square PVC posts to fit over round steel posts in a sleeve like manner. The post adapters consist of a base of approximately 5 inches in width, 1 inch in height with a collar built into the base of approximately 3 inches to 4 inches in diameter. The collar allows the adapter to fit over the round steel post. The square posts in turn are placed over the round steel posts fitted with the adapters allowing the square posts to fit securely.

The rail adapters consist of a circular cylinder 12 inches in height that has an attached piece described as a flange on top. The flange resembles a squared U shape and is 5 inches in height and 4 inches in length. The rail adapters fit inside the posts and the beams fit into the top part or flange of the product.

The rail connectors are designed to fit over the rail adapters and resemble an expanded version of the flange part of the rail adapter. The rail connectors have two parts, each a mirror image of the other. The height of both parts is 6 inches and the width is 2 inches. The rail connectors connect additional beams. The applicable subheading for the steel post adapters, rail adapters and rail connectors will be 7308.90.9590, Harmonized Tariff Schedule of the United States (HTSUS), which provides for structures (excluding prefabricated buildings of heading 9406) and parts of structures (for example, bridges and bridge sections, lock gates, towers, lattice masts, roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, shutters, balustrades, pillars and columns) of iron or steel; plates, rods, angles, shapes, sections, tubes and the like, prepared for use in structures of iron or steel, other, other, other, other, other. The rate of duty will be free.

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 Mary Ellen Laker at (646) 733-3020.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division