Mr. Christopher Constantine
Unique Logistics International (BOS) Inc.
35 Village Road, Suite 701
Middleton, MA 01949

RE: The tariff classification of abrasive sanding plates from China.

Dear Mr. Constantine:

In your letter dated February 17, 2021, you requested a tariff classification ruling on behalf of your client, Acme United Corporation.

The merchandise under consideration is four styles of abrasive sanding plates, referred to as the D-Maxx Palm, Orbital, Multitool, and Corner. Samples were submitted with your ruling request and will be returned to you.

The D-Maxx Palm is square in shape and measures approximately 11 centimeters wide by 11 centimeters long by .3 centimeters thick at its widest points.

The D-Maxx Orbital is disc-shaped and measures approximately 12.5 centimeters in diameter by .3 centimeters thick at its widest points

The D-Maxx Multitool is triangular in shape and measures approximately 7 centimeters wide by 7 centimeters long by .3 centimeters thick at its widest points.

The D-Maxx Corner is of a flattened teardrop shape and measures approximately 13.6 centimeters long by 10 centimeters wide by .3 centimeters thick at its widest points.

From the information you provided, the D-Maxx sanding plates consist of synthetic diamond agglomerated with metal which has been affixed to a steel plate. The back of the plate features a hook-and-loop surface. The hook-and-loop surface allows the plate to be attached to compatible power sanders in order to sand sheetrock, wood, and light metal surfaces.

The applicable subheading for the D-Maxx Palm, D-Maxx Orbital, D-Maxx Multitool, and D-Maxx Corner sanding plates will be 6804.21.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Millstones, grindstones, grinding wheels and the like, without frameworks, for grinding, sharpening, polishing, trueing or cutting, hand sharpening or polishing stones, and parts thereof, of natural stone, of agglomerated natural or artificial abrasives, or of ceramics, with or without parts of other materials: Other millstones, grindstones, grinding wheels and the like: Of agglomerated synthetic or natural diamond: Other.” The general rate of duty will be Free.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 6804.21.0090, 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 6804.21.0090, 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 and, respectively.

The merchandise in question 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 (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, and you can search AD/CVD deposit and liquidation messages using CBP’s AD/CVD Search tool at

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

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 Nicole Sullivan at [email protected].


Steven A. Mack
National Commodity Specialist Division