Ms. Chandanie Gunathilake
Sourcing Specialist
IPS Corporation
500 Distribution Parkway
Collierville, TN 38017

RE: The tariff classification of shower grates from China

Dear Ms. Gunathilake:

In your letter dated September 7, 2022, you requested a tariff classification ruling on shower grates. Product descriptions and photographs were provided for our review.

The articles under consideration are identified as shower grates, IPS item numbers 63643 (Model No. ABA44010MB), 69693 (Model No. ABA7101VB), 69125 (Model No. ABA7137ORB), 59614 (Model No. ABA5149ORB), and 59525 (Model No. ABAB7101SN). All of the subject grates are used in residential showers with floor tiling for draining water. In your letter you described each item in its condition as imported. IPS item number 63643 is a Round Stamped Stainless Steel Snap-In Shower Grate/Strainer with a matte black finish. The grate measures 4¼” in diameter. IPS item number 69693 is a Round Stamped Brass Snap-In Shower Grate/Strainer with a Venetian bronze plated finish. The grate measures 4¼" in diameter. IPS Item No. 69125 is a Round Stamped Brass Shower Grate/Strainer with two stainless steel screws (7135 Series). The grate features an oil rubbed bronze plated finish and measures 4¼” in diameter. IPS item number 59614 is a Shower Grate/Strainer that consists of a round stamped brass grate, a brass crown, a steel plate, and two stainless steel screws. The grate features an oil rubbed bronze plated finish and measures 3¼” in diameter. IPS item number 59525 is a Round Stamped Brass Snap-In Shower Grate/Strainer with a satin nickel plated finish. The grate measures 4¼” in diameter. Consideration was given to classifying IPS item numbers 63643, 69693, 69125, 59614, and 59525 as sanitary ware in subheading 7324.90.0000, Harmonized Tariff Schedule of the United States (HTSUS), as you proposed. The standard for plumbing supply fittings, ASME A112.18.1/CSA B125.1, defines a plumbing accessory as, “a component that can, at the discretion of the user, be readily added, removed, or replaced, and that, when removed, will not prevent the fitting from fulfilling its primary function.” We note that the subject shower grates are available as “accessory purchases” and come in various shapes, styles and finishes so the purchaser or installer can easily change the grate to one that matches features such as the shower head, controls, and tile. Also, even without the grate, the drain fixture can still perform its primary function of directing water from the shower to the drainpipe. As such, it is our opinion that these grates are accessories to a drain, not a part of the drain. Accessories to sanitary ware are not classified under heading 7324, HTSUS.

IPS item number 69125 is comprised of brass and stainless steel components, and IPS item number 59614 is comprised of brass, steel and stainless steel components that are classified in different headings. Classification of merchandise under the HTSUS is in accordance with the General Rules of Interpretation (GRIs), taken in order. GRI 1 provides that classification shall be determined according to the terms of the headings and any relative section or chapter notes. Since no one heading in the tariff schedules covers the components that comprise item numbers 69125 and 59614 in combination, GRI 1 cannot be used as a basis for classification. GRI 3(b) provides that mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale shall be classified as if they consisted of the material or component which gives them their essential character.   We note that IPS item numbers 69125 and 59614 are composite articles comprised of more than one metal. Regarding the classification of composite articles, Section XV, Note 7 of the HTSUS states that “articles of base metal containing two or more base metals are to be treated as articles of the base metal predominating by weight over each of the other metals”. Based on the information provided to our office, the metal in these shower grates that predominates by weight is brass. Therefore, IPS item numbers 69125 and 59614 will be classified under heading 7419, HTSUS, which provides for other articles of copper. The applicable subheading for IPS item number 69693 (Model No. ABA7101VB), IPS item number 69125 (Model No. ABA7137ORB), IPS item number 59614 (Model No. ABA5149ORB), and IPS item number 59525 (Model No. ABAB7101SN) will be 7419.80.5010, HTSUS, which provides for other articles of copper, other…brass plumbing goods not elsewhere specified or included. The rate of duty will be free. The applicable subheading for IPS item number 63643 (Model No. ABA44010MB) will be 7326.90.8688, HTSUS, which provides for other articles of iron or steel, other…other. The rate of duty will be 2.9 percent ad valorem.

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

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 7419.80.5010 and 7326.90.8688, 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 7419.80.5010 and 7326.90.8688, 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.

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 Ann Taub at [email protected].


Steven A. Mack
National Commodity Specialist Division