CLA-2-73:OT:RR:NC:N1:121
Melissa Auell
Auell Consulting
6304 South Ross Road
Morrison, CO 80465
RE: The tariff classification of stainless steel and plastic concrete anchor products from China
Dear Ms. Auell:
In your letter dated January 12, 2021 you requested a tariff classification ruling on behalf of your client Shur-Tite Products Inc.
The merchandise under consideration is described as a “concrete anchor product” which includes four specialized parts; a concrete anchor, concrete anchor extension, concrete anchor shank, and concrete anchor cap. All four items are used for mounting traffic delineation posts on roads, highways, and freeways.
Item 1 is identified as a concrete anchor. It consists of an anchor screw that is made of 304 stainless steel. The anchor is approximately 3 inches high and 2 inches wide with internal threads. It is designed to be mounted into concrete to hold and mount a traffic delineator.
Item 2 is identified as a concrete anchor extension. It is an optional anchor extension screw made of 304 stainless steel. The anchor extension is approximately 2.5 inches high and 2 inches wide with internal threads. It is designed to be attached to the bottom of the concrete anchor to extend the depth of the anchor if a deeper depth is desired.
Item 3 is identified as a concrete anchor shank. The shank is a stud that is threaded on one end and is tapered flat with a single eye hole at the opposite end. It is approximately 3.2 inches tall and 0.7 inches in diameter. The concrete anchor shank is made of 304 stainless steel and is designed to be threaded into the concrete anchor to provide an attachment point for a traffic delineator post.
Item 4 is identified as a concrete anchor cap. It is a plastic screw cap composed of nylon with glass fill. The cap can be screwed into the concrete anchor when the anchor is not in use to keep it clean and free of debris.
The applicable subheading for the stainless steel concrete anchor and anchor extension will be 7318.19.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: Threaded articles: Other. The rate of duty will be 5.7% ad valorem.
The applicable subheading for the stainless steel concrete anchor shank will be 7318.15.5030, HTSUS, which provides for Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: Threaded articles: Other screws and bolts, whether or not with their nuts or washers: Studs: Of stainless steel. The duty rate will be free.
The applicable subheading for the plastic concrete anchor cap will be 3923.50.0000, HTSUS, which provides for Stoppers, lids, caps and other closures, of plastics. The general rate of duty will be 5.3% ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 7318.19.0000, 7318.15.5030, and 3923.50.0000, 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 7318.19.0000, 7318.15.5030, and 3923.50.0000, 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-productschina, respectively.
The concrete anchor shank may be subject to antidumping duties and countervailing duties (AD/CVD). Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and Compliance office in the International Trade Administration of the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP). You can contact them at https://trade.gov/enforcement/ (click on “Contact Us”). For your information, you can view a list of current AD/CVD cases at the United States International Trade Commission website at https://www.usitc.gov/trade_remedy/documents/orders.xls, and you can search AD/CVD deposit and liquidation messages using CBP’s AD/CVD Search tool at https://aceservices.cbp.dhs.gov/adcvdweb.
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 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 Jennifer Jameson at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division