Mr. Tom Des Champs
Dedoes Industries LLC
1060 W. West Maple Road
Walled Lake, MI 48390

RE: The tariff classification of paint test panels from Belgium

Dear Mr. Des Champs:

In your letter dated May 10, 2018, you requested a tariff classification ruling. A representative sample was included with your submission and will be retained by this office.

The products to be imported are paint test panels used in the automotive refinishing industry. These nonalloy steel rectangular shaped panels, which measure 152.40 mm (L) x 95 mm (W), have rounded corners and are coated on both sides with plastic. They also include five painted squares along the top on one side and a drill hole. You indicate that the body shop sprays the test panels with paint prior to painting an automobile to ensure that the color is accurate.

The applicable subheading for the paint test panels will be 7212.40.1000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for flat-rolled products of iron or nonalloy steel, of a width of less than 600 mm, clad, plated or coated, painted, varnished or coated with plastics, of a width of less than 300 mm. The rate of duty will be free.

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

On March 8, 2018, President Trump proclaimed additional tariffs and quotas on a number of steel and aluminum mill products. Exemptions have been made on a temporary basis for some countries. Quantitative limitations or quotas may apply for certain exempted countries and can also be found in Chapter 99. Additional duties for steel of 25 percent and for aluminum of 10 percent are reflected in Chapter 99, subheading 9903.80.01 for steel and subheading 9903.85.03 for aluminum. Products classified under HTS subheading 7212.40.1000, may be subject to additional duties or quota. At the time of importation, you must report the Chapter 99 number applicable to your product classification in addition to the Chapter 72, 73 or 76 number listed above.

The Proclamations are subject to periodic amendment of the exclusions, so you should exercise reasonable care in monitoring the status of goods covered by the Proclamations and the applicable Chapter 99 numbers.

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 Mary Ellen Laker at [email protected]


Steven A. Mack
National Commodity Specialist Division