Mr. Mark Anspach
Deck Weapons LLC
7901 4 N, STE 300 St Petersburg, FL 33702

RE: The tariff classification of a carbon fiber telescoping pole from China.

Dear Mr. Anspach:

In your letter dated March 22, 2023, you requested a tariff classification ruling.

The merchandise under consideration is referred to as the Pole-Arm.  A sample was submitted with your ruling request and was forwarded to the Customs and Border Protection Laboratory for analysis.  This analysis has been completed. 

The Pole-Arm is a telescoping pole which measures approximately 2.7 centimeters in diameter by 152 centimeters long when collapsed, reaching approximately 274 centimeters when fully extended. It features EVA foam grips and is designed to be fitted with a variety of attachments, such as brushes, mops, and squeegees, in order to clean boats.  From the information you provided, the Pole-Arm is made of PAN fiber which has not been fully carbonized.

Laboratory analysis has determined that the Pole-Arm is comprised of fully carbonized carbon fiber.

The applicable subheading for the Pole-Arm will be 6815.13.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Articles of stone or of other mineral substances (including carbon fibers, articles of carbon fibers and articles of peat), not elsewhere specified or included:  Carbon fibers; articles of carbon fibers for non-electrical uses; other articles of graphite or other carbon for non-electrical uses:  Other articles of carbon fibers.”  The rate of duty will be Free.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 6815.13.0000, 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 6815.13.0000, HTSUS, listed above.

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

This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Nicole Sullivan at [email protected].


Steven A. Mack
National Commodity Specialist Division