CLA-2-83:OT:RR:NC:N1:121
Scott Lindsey
Sysco
1390 Enclave Pkwy
Houston, TX 77077
RE: The tariff classification of aluminum locking brackets from China
Dear Mr. Lindsey:
This replaces Ruling Number N327091 dated July 26, 2022. Ruling Number N327091 incorrectly noted the Section 301 additional trade remedies rate. The correct additional duty rate for products of China classified under subheading 8301.40.6060, HTSUS, unless specifically excluded is 7.5% ad valorem. A complete corrected ruling follows.
In your letter dated July 14, 2022, you requested a tariff classification ruling.
The merchandise under consideration is two styles of wall mounted aluminum locking brackets (product numbers 100122 and 100123). Both styles are identical except that product number 100122 is mounted using adhesive tape and product number 100123 is mounted using mounting screws. Each locking bracket is designed to mount and secure soap/shampoo dispenser bottles in hotel bathroom areas. Once mounted, the mechanical locking lid is closed over a specially designed soap/shampoo bottle, securing the bottle in place. Hotel personnel can access the bottle to replace or refill it by unlocking the bracket with the included specially designed keys.
The applicable subheading for the aluminum locking brackets, product numbers 100122 and 100123, will be subheading 8301.40.6060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Padlocks and locks (key, combination or electrically operated) of base metal: Other locks: Other: Other. The rate of duty will be 5.7 percent ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8301.40.6060, 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 8301.40.6060, 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 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