CLA-2-82:OT:RR:NC:N1:118
Mr. Robert Um
OEC Logistics Inc.
133-33 Brookville Blvd. Suite 308
Rosedale, NY 11422
RE: The tariff classification of grill torches, a bottle stand and adaptor hose from China.
Dear Mr. Um:
In your letter dated March 3, 2020, on behalf of our client, Grillblazer, LLC, you requested a tariff classification ruling.
The merchandise under consideration are two styles of grill torches, a bottle stand and adaptor hose. You have stated that at the time of importation, each grill torch will be bulk packed while each accessory will be bulk packed separately.
The two grill torches are identified as GrillGun and Su-VGun. Both models are hand-held, propane-powered torches. The GrillGun measures 21 inches in length and is made of steel with some brass components. It is designed and advertised to light up outdoor charcoal grills, fireplaces, campfires or for searing meat. The Su-VGun is similar to the GrillGun, with the only difference being the total length measuring at 14.5 inches. The shorter barrel is designed to create a tighter flame for close work when searing meats that have been cooked sous-vide. Both grill torches will be imported without a propane tank.
The bottle stand is made of steel and serves as an accessory to the GrillGun torch. When a propane bottle is attached to the GrillGun, the bottle stand can be fitted around the bottom of the tank. This prevents the GrillGun from tilting over and holds it upright. The adapter hose is a typical propane hose. It measure 8 feet in length and is made of nitrile rubber. Both ends have standard brass connectors with O-ring seals. This hose is used when the grill torches are used with a 20 or 30 pound propane tank.
The applicable subheading for the adapter hose will be 4009.12.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for tubes, pipes and hoses, of vulcanized rubber, other than hard rubber, with or without their fittings: not reinforced or otherwise combined with other materials: with fittings. The general rate of duty will be 2.5 percent ad valorem.
The applicable subheading for the bottle stand will be 7326.90.8688, HTSUS, which provides for other articles of iron or steel, other, other…other. The general rate of duty will be 2.9 percent ad valorem.
The applicable subheading for the grill torches, identified as GrillGun and Su-VGun, will be 8205.60.0000, HTSUS, which provides for handtools (including glass cutters) not elsewhere specified or included; blow torches and similar self-contained torches; vises, clamps and the like, other than accessories for and parts of machine tools; anvils; portable forges; hand- or pedal-operated grinding wheels with frameworks; base metal parts thereof: other handtools (including glass cutters) and parts thereof: blow torches and similar self-contained torches, and parts thereof. The general rate of duty will be 2.9% ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 4009.12.0050, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 4009.12.0050, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 7326.90.8688 and 8205.60.0000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheadings 7326.90.8688 and 8205.60.0000, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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 Anthony E. Grossi at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division