CLA-2-73:OT:RR:NC:N1:117
Ms. Julie C. Vair
Senior Consultant
Tradewin
1015 Third Avenue
12th Floor
Seattle, WA 98104
RE: The tariff classification of steel framed bathroom pods from China
Dear Ms. Vair:
In your letter dated April 2, 2015, on behalf of your client, OneBuild, you requested a tariff classification ruling.
The products you plan to import are described as steel framed bathroom pods or structural components imported for permanent installation into hotels, student housing or multifamily buildings that are built onsite. The bathroom pods are stated to be separate steel structural units whose steel frames are made from hollow steel structural sections that are welded or bolted together. The dimensions are generally 10 – 12 feet in length, 7 feet in width and 8 feet in height. The typical make up of each bathroom unit, in addition to the framing, includes steel floors, internal walls and ceilings of compressed cement sheets or similar materials, wiring and piping set into walls, and tiles, lighting and plumbing fixtures. There are no windows or doors included in the pods. According to the information submitted, the pods cannot be operated independently of the building into which they are intended to be installed since they require power and utilities supplied by the building through piping and wiring. The pods, in their condition as imported, are stated to be not fully enclosed or weatherproof, and therefore incapable of being used individually in a stand–alone operation.
The applicable subheading for the steel framed bathroom pods will be 7308.90.9590, Harmonized Tariff Schedule of the United States (HTSUS), which provides for structures (excluding prefabricated buildings of heading 9406) and parts of structures (for example, bridges and bridge sections, lock gates, towers, lattice masts, roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, shutters, balustrades, pillars and columns) of iron or steel; plates, rods, angles, shapes, sections, tubes and the like, prepared for use in structures, of iron or steel: other, other, other, other, other. The rate of duty will be free.
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 Mary Ellen Laker at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division