Mr. Peter Salvato
Metro Customs Brokers
500 Merrick Road
Lynbrook, NY 11563
RE: The tariff classification of five various styles of vacuum cleaner brushes from China.
Dear Mr. Salvato:
In your letter dated June 28, 2018, you requested a tariff classification ruling on behalf of your client, Steel City Vacuum Company, Inc.
Samples were provided for all of the articles and will be returned separately.
The items under consideration are listed as “DUST BRUSH - 1 1/4", HORSE HAIR, ECONOMY, BLA” (part number 32-1640-68), “FLOOR BRUSH - FITALL, W/METAL ELBOW, HORSE H” (part number DS-306B), “FLOOR BRUSH - KENMORE, CANISTER, REPLACEMENT” (part number 74214), “BRUSH ROLL - DYSON DC07, DC14, UPRIGHT, REPLA” (part number 10-3400-25), and “BRUSH ROLL - DYSON, DC-17, ANIMAL, GEARED TYP” (part number 10-3404-08).
The first item, part number 32-1640-68, is a round brush attachment for a vacuum. The body of this item is plastic with a brush encircling the base. You indicate that this item is made of 70 percent horsehair and 30 percent polypropylene (PP).
The second item, part number DS-306B, appears to be a vacuum accessory. It has a wide plastic head, which connects to a metal elbow. Around the base of the plastic head is a brush that you indicate is made from 100 percent horsehair.
The third item, part number 74214, appears to be a vacuum accessory. This article is primarily constructed of plastic and features a wide head. On the base, it has three rows of bristles, a short row at the front, a long split row in the middle, and a medium length split row in the back. You state it is made of 70 percent horsehair and 30 percent PP.
The fourth item, part number 10-3400-25, is a plastic beater brush roll with two end caps. The main item has a slight twist with blue tufts of bristles along both edges. The end caps each feature one tuft of the blue bristles. You indicate this is made of 100 percent nylon.
The fifth item, part number 10-3404-08, is a cylindrical beater brush roll. It has two rows of red tufts of bristles that make a twist around the body of this article. You indicate this is made of 100 percent nylon.
The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official interpretation of the Harmonized System at the international level. While not legally binding nor dispositive, the ENs provide guidance on the scope of each chapter, heading and certain subheadings of the Harmonized Tariff Schedule of the United States (HTSUS), and are generally indicative of the proper interpretation of such headings and subheadings. Within the ENs for heading 9603, it states this heading includes “[b]rushes for electrical household appliances (e.g., floor polishers or waxers, vacuum cleaners).” Additionally, for vacuum “auxiliary devices (accessories) (for brushing, polishing, insecticide spraying, etc.) or interchangeable parts (carpet devices, rotary brushes, multiple-function suction heads, etc.) … [w]hen presented separately, they are classified by reference to their nature.”
The applicable subheading for these five vacuum brushes will be 9603.50.0000, HTSUS, which provides for “[b]rooms, brushes (including brushes constituting parts of machines, appliances or vehicles), hand-operated mechanical floor sweepers, not motorized, mops and feather dusters; prepared knots and tufts for broom or brush making; paint pads and rollers; squeegees (other than roller squeegees): [o]ther brushes constituting parts of machines, appliances or vehicles.” The general rate of duty is 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 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 Kristopher Burton at firstname.lastname@example.org.
Steven A. Mack
National Commodity Specialist Division