CLA-2-73:OT:RR:NC:N1:113
Mr. Adam N. Riddle
Drummond Industries Ltd.
1135 Quayside Drive
New Westminster, Washington V3M 6J4
Canada
RE: The tariff classification of stand brackets made in China
Dear Mr. Riddle:
In your letter dated February 25, 2020, you requested a tariff classification ruling on stand brackets. In response to our request for additional information, this office received answers to our questions in your letter dated April 8, 2020. Pictures of the stand brackets were provided for our review.
In your letter you described the products under consideration as stand brackets that are composed of steel and are designed to enable a user to build their own target stands. The stand brackets are sold in pairs and can be combined with lengths of 2" x 2" wood to assemble a sawhorse-style stand from which the shooting targets can be hung. Hanging hardware for the targets, such as chains, bolts, and washers, as well as the lengths of wood needed to assemble the stand, are sold separately from the brackets.
You indicated that all manufacturing processes on the steel are performed in China. The steel is stamped, cut, welded, powder coated and boxed in China. The finished stand brackets are shipped from China to Canada. In their condition as imported into Canada, the powder coated stand brackets are complete and ready for retail sale inside case cartons. No additional manufacturing operations are performed in Canada. You stated that “Only individually-sold product is repackaged for sale as items are received in case boxes.” The stand brackets are complete and packed ready for sale at the time of import into the United States.
The applicable subheading for the stand brackets will be 7326.90.8688, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel, other, other…other. The rate of duty will be 2.9 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.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 7326.90.8688, 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 subheading 7326.90.8688, 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.
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 Ann Taub at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division