CLA-2-84:OT:RR:NC:N1:104

Ms. Patricia M. Choo
Itochu International
1251 Avenue of the Americas
New York, NY 10020

RE: The tariff classification of Blades and Float Pans from Ireland and China

Dear Ms. Choo:

In your letter dated April 8, 2019, on behalf of Multigrip Inc., you requested a tariff classification ruling.

The importation consists of blades and float pans that are used as attachments for walk-behind power trowels and ride-on power trowels. Power trowels are used for concrete finishing work. The blades are made of a high carbon, high performance tool steel. There are two types of blades, a finish blade which has a thickness that ranges from .062 to .092 to ensure a long life and smooth operation. The other blade is called a combination blade which has a thickness ranging from .075 (Standard) to .092 (Enduro) which allows for a longer life and greater versatility. Float pans increase the ability to achieve a flatter floor. There are a variety of float pan options that ranges from Z-clip to Latch pin and Domed (Flat) to Superflat.

The applicable subheading for the blades and float pans will be 8479.90.9450, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Parts: Other: Other: Of machinery for public works, building or the like”. The rate of duty will be free.

Effective July 6, 2018, the Office of the United States Trade Representative (USTR) imposed an additional tariff on certain products of China classified in the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(b), HTSUS. The USTR imposed additional tariffs, effective August 23, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(d), HTSUS. Subsequently, the USTR imposed further tariffs, effective September 24, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(f) and U.S. Note 20(g), HTSUS. For additional information, please see the relevant Federal Register notices dated June 20, 2018 (83 F.R. 28710), August 16, 2018 (83 F.R. 40823), and September 21, 2018 (83 F.R. 47974). Products of China that are provided for in subheading 9903.88.01, 9903.88.02, 9903.88.03, or 9903.88.04 and classified in one of the subheadings enumerated in U.S. Note 20(b), U.S. Note 20(d), U.S. Note 20(f) or U.S. Note 20(g) to subchapter III shall continue to be subject to antidumping, countervailing, or other duties, fees and charges that apply to such products, as well as to those imposed by the aforementioned Chapter 99 subheadings.

Products of China classified under subheading 8479.90.9450, HTSUS, unless specifically excluded, are subject to the additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01, in addition to subheading 8479.90.9450, HTSUS, listed above.

The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading.

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 Patricia O’Donnell at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division