Ms. Maria Villasmill
AA Metals Inc.
116116 Landstar Blvd.
Orlando, FL 32824

RE:      The tariff classification of aluminum sheet from Turkey, United Arab Emirates, Bahrain, China, Oman, and Malaysia 

Dear Ms. Villasmill:

In your letter dated June 16, 2023, you requested a tariff classification ruling.

The product to be imported is identified as aluminum coil for use in the manufacture of gutters. According to your submission, this sheet will be made from either type 3105 or 4107 aluminum alloy and has not been coated or clad. The sheet has a thickness ranging from 0.01 to 0.0615 inch (0.254 to 1.56 millimeters) and a width ranging from 10.5 to 61 inches (266.7 to 1549.4 millimeters). After importation, the sheet will be de-coiled and fed into a machine where it is roll formed into gutters.

You suggest classification of the aluminum coils in subheading 7610.90.0020, Harmonized Tariff Schedule of the United States (HTSUS), which provides for aluminum structures (excluding pre-fabricated buildings of heading 9406) and parts of structures (for example, bridges and bridge-sections, towers, lattice masts, roofs, roofing frameworks, aluminum doors and windows and their frames and thresholds for doors, balustrades, pillars and columns); aluminum plates, rods, profiles, tubes and the like, prepared for use in structures, other, sheet-metal roofing, siding, flooring, and roof guttering and drainage equipment. We disagree. At the time of importation, the product in question is merely aluminum sheet in coil form that has not been prepared for use in structures.

The applicable subheading for the aluminum sheet will be 7606.12.3091, HTSUS, which provides for aluminum plates, sheets and strip, of a thickness exceeding 0.2 mm): rectangular (including square): of aluminum alloys: not clad, with a thickness of 6.3 mm or less: other: heat-treatable industrial alloys of a kind described in statistical note 6 to this chapter. The rate of duty will be 3 percent ad valorem.

The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. You should also be aware that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.

Please be advised that aluminum sheet from Turkey, Oman, Bahrain, and China 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 (ITA) and are separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP). General information regarding the ITA and AD/CVD can be found at  The ITA’s “Guide on How to File for an Antidumping/Countervailing Duty Scope Ruling Request” is available at 

On March 8, 2018, Presidential proclamations 9704 and 9705 imposed 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 9903.85.01 for aluminum. Products classified under subheading 7606.12.3091, HTSUS, may be subject to additional duties or quota. At the time of importation, you must report the Chapter 99 subheading applicable to your product classification in addition to the Chapter 72, 73 or 76 subheading 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 subheadings.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 7606.12.3091, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 7606.12.3091, 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.

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 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 Angelia Amerson at [email protected].


Steven A. Mack
National Commodity Specialist Division