CLA-2-84:OT:RR:NC:1:104
Mr. Steven W. Lange
Continental Commercial Products, LLC
305 Rock Industrial Park Dr.
Bridgeton, MO 63044
RE: The tariff classification of cleaning equipment from China, Thailand and the United States
Dear Mr. Lange:
In your letter dated September 23, 2009 you requested a tariff classification ruling.
Your firm intends to import wringer and bucket components from China and Thailand into the United States. Once in the United States, the components will undergo further processing in order to assemble them into a wringer/bucket combo pack. You have requested a ruling as to the tariff classification of these goods under the following three scenarios:
(1) The powder coated steel handle is imported from China. It is a component of item number SW12/Side Press Wringer. Subsequent to importation, the imported component is assembled a domestically produced molded plastic wringer. Drawings submitted show that, while referred to as a “handle”, the device in question consists of more than a metal shaft to be grasped by the user to hold the wringer or to carry it from place to place. Rather, the “handle” mechanism enables the user to apply the pressure necessary for the squeezing process.
(2) Castors are imported from Thailand. They are components of item number 335-3YM/Mop Bucket. The castors are made of metal with rubber wheels. Once in the United States, the castors will be assembled to a domestically produced molded plastic bucket.
(3) The finished side press mop wringer (item number SW12) and bucket (item number 335-3YM) are packaged together in the United States into item number 226-312YW/Combo Pack. In your supplemental email message to this office dated September 30, 2009, you indicate that item number 226-312YW/Combo Pack will be exported to Canada, Mexico and other parts of the world.
You have proposed classification for the handle/squeezing mechanism that enables the user to apply the pressure necessary for the squeezing process under subheading 7323.99.9060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for table, kitchen or other household articles and parts thereof, of iron or steel…other, other, not coated or plated with precious metal, other, other, other. Heading 7323 covers a wide range of iron or steel household articles that are not more specifically provided for elsewhere in the HTSUS. The subject handle/squeezing mechanism is not classifiable in heading 7323, HTSUS, because it is provided for more specifically in another heading of the HTSUS.
The applicable subheading for the castors will be 8302.20.0000, HTSUS, which provides for base metal mountings, fittings and similar articles…castors, and parts thereof. The rate of duty will be 5.7% ad valorem.
Articles classifiable under subheading 8302.20.0000, HTSUS, which are products of Thailand, may be entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations. The GSP is subject to modification and periodic suspension, which may affect the status of your transaction at the time of entry for consumption or withdrawal from warehouse. To obtain current information on GSP, check our Web site at www.cbp.gov and search for the term “GSP”.
The applicable subheading for the handle/squeezing mechanism described above will be 8479.90.9496, HTSUS, which provides for Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Parts: Other…Other. The rate of duty will be free.
In general, item number 226-312YW/Combo Pack is classifiable in subheading 3926.90.1000, HTSUS, which provides for other articles of plastics and articles of other materials of headings 3901 to 3914: other: buckets and pails.
Should you be interested in obtaining a NAFTA advance ruling, please note that per Subpart I [Advance Ruling Procedures], Section 181.92(5)(i) [Definitions and general NAFTA advance ruling practice.], this Office has no authority to issue rulings on goods exported from the U.S. to other NAFTA countries, i.e., Canada or Mexico. A list of addresses from which advance rulings for exports into Canada or Mexico can be requested is located at the U.S. Customs and Border Protection website at www.cbp.gov (click on Trade, Trade Programs, International Agreements, International Free Trade Agreements, North American Free Trade Agreement, Advance Rulings).
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 http://www.usitc.gov/tata/hts/.
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 Patricia O’Donnell at (646) 733-3011.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division