CLA-2-73:OT:RR:NC:N4:422
Mr. Peter Bogard
Neville Peterson LLP
1400 16th Street, N.W. Suite 350
Washington DC 20036
RE: The tariff classification of unfinished trash cans of galvanized steel from China.
Dear Mr. Bogard:
In your letter dated July 27, 2018, on behalf of Behrens Manufacturing, Inc., you requested a tariff classification ruling.
You submitted illustrations and a detailed description of five styles of unfinished trash cans made of galvanized steel. The galvanized steel parts are cut from a coil, stamped and drawn, prior to importation, to the point where the resulting parts can only be used in the manufacture of of a trash can. After importation, the side pieces formed in China are corrugated and folded or joined to complete the body of the trash can. The partially assembled body is then sent through a swedger to form the side walls into a tapered cylinder shape, and the top of the body is curled over a wire ring. The bottom is then attached to the narrow end of the body. Handles or bales are then attached.
The first item is identified as Model 1270, a 30-gallon trash can and cover, which consists of four parts, two sides, a bottom and a cover.
The second item is identified as Model 1211, a 20-gallon trash can and cover, which consists of four parts, two sides, a bottom and a cover.
The third and fourth items are identified as Models 6110 and 6210, both 10-gallon trash cans with covers which consist of four parts, two sides, a bottom and a cover.
The fifth item is identified as Model 6106, a 6-gallon trash can and cover which consists of 4 parts, two sides, a bottom and a cover.
The sixth item is identified as Model 6104, a 4-gallon trash can and cover which consists of four parts, two sides, a bottom and a cover.
In the future, please limit your ruling request to a maximum of 5 items of the same class or kind.
According to GRI 2(a), if an incomplete article has the essential character of the complete or finished article, it is classified as the complete or finished article. These parts do convey the essential character of the finished trash cans and can only be used to produce finished trash cans.
The applicable subheading for unfinished trash can Models 1270, 1211, 6110, 6210, 6106 and 6104 will be 7323.99.9080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “…other household articles…of iron…: other: other: not coated or plated with precious metal: other: other…other.” The rate of duty will be 3.4 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 the 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 Sandra Carlson at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division