CLA-2-73:OT:RR:NC:N1:117
Ms. Susan Kohn Ross
Mitchell Silberberg & Knupp LLP
11377 W. Olympic Boulevard
Los Angeles, CA 90064
RE: The tariff classification of steel doors and replacement handles from China
Dear Ms. Ross:
In your letter dated August 7, 2017, you requested a tariff classification ruling on behalf of your client, Universal Motion Components Co., Inc.
The products to be imported are four different styles of weathertight steel doors and dog-style replacement handles for the subject doors. The doors (4-Dog Style- SKU: UMC-WTD-4D,
6-Dog Style- SKU: UMC-WTD-6D, Lever Arm Style- SKU: UMC-WTD-LA and Quick Acting Style-SKU: UMC:WTD-QA) are installed on the decks of barges, workboats, commercial fishing boats, etc. and provide access from one area of a vessel to another. They are made of steel plate that has been painted and will be imported as a finished product, fully assembled and ready for installation. Three of the four doors feature 6 dog-style handles with the exception of the 4-Dog Style which has 4-dog style handles.
The applicable subheading for the steel doors will be 7308.30.5050, 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, doors, windows and their frames and thresholds for doors, other, other. The rate of duty will be free.
The replacement handles (Dog Handle Replacements- SKU: UMC-WTD-DOG) are made from cast steel with stainless steel through shafts. These handles are used on both the 4-dog and 6-dog style doors and are available in left and right hand configurations.
You suggest classification of the replacement handles in subheading 7308.90.9590, HTSUS, as parts of structures. Section XV, Note 2 states the following: “Subject to the preceding paragraph and to Note 1 to Chapter 83, the articles of Chapter 82 and 83 are excluded from Chapters 72 to 76 and 78 to 81.” The subject steel door handles meet the terms of heading 8302, HTSUS, which provides, in pertinent part, for mountings and fittings suitable for vessels. Consequently, they are excluded from classification in heading 7308.
The applicable subheading for the replacement handles will be 8302.49.6055, HTSUS, which provides for base metal mountings, fittings and similar articles, other mountings, fittings and similar articles, and parts thereof, other, other, of iron or steel, of aluminum or of zinc, other, for aircraft, vessels and other vehicles (except motor vehicles) of section XVII. The duty rate will be 5.7 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 https://hts.usitc.gov/current.
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 [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division