CLA-2-73:OT:RR:NC:N1:113
Mr. Albert F. Tien
China Manufacturing Network, LLC, DBA Global Manufacturing Network
17891 Sky Park Circle, Suite 23K
Irvine, CA 92614
RE: The tariff classification of a steel box with inserted screws from China
Dear Ms. Tien:
In your letter dated October 3, 2018, you requested a tariff classification ruling on a steel box with inserted screws. Photographs and specification drawings were submitted for our review.
The subject article is identified as 400-12405. You described the article as a hinged steel box that measures 14 inches in length by 14 inches in width. The box features approximately 34 steel studs that are inserted and positioned into the back of the box. The box is to be directly mounted on the wall. This box was uniquely designed and will supply power and control for a commercial electrical door lock.
You proposed classifying 400-12405 under 8301.60.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Padlocks and locks (key, combination or electrically operated), of base metal: keys and parts of any of the foregoing articles, of base metal: Parts. However, this office disagrees. The steel box under consideration is not recognizable as a part of a lock in its condition as imported. The Explanatory Notes for 8301, HTSUS, require that the item be clearly recognizable as such, in order to be classified under heading 8301, HTSUS. Therefore heading 8301, HTSUS, does not apply. Noting the above, the subject steel box with screws is classifiable under heading 7326, HTSUS, which provides for Other articles of iron or steel.
The applicable subheading for the steel box with inserted screws, 400-12405, 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 on World Wide Web at https://hts.usitc.gov/current.
Effective July 6, 2018, the Office of the United States Trade Representative (USTR) imposed an additional tariff on certain products of China classified in the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(b), HTSUS. The USTR imposed additional tariffs, effective August 23, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(d), HTSUS. Subsequently, the USTR imposed further tariffs, effective September 24, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(f) and U.S. Note 20(g), HTSUS. For additional information, please see the relevant Federal Register notices dated June 20, 2018 (83 F.R. 28710), August 16, 2018 (83 F.R. 40823), and September 21, 2018 (83 F.R. 47974). Products of China that are provided for in subheading 9903.88.01, 9903.88.02, 9903.88.03, or 9903.88.04 and classified in one of the subheadings enumerated in U.S. Note 20(b), U.S. Note 20(d), U.S. Note 20(f) or U.S. Note 20(g) to subchapter III shall continue to be subject to antidumping, countervailing, or other duties, fees and charges that apply to such products, as well as to those imposed by the aforementioned Chapter 99 subheadings.
Products of China classified under subheading 7326.90.8688, HTSUS, unless specifically excluded, are subject to the additional 10 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 7326.90.8688, HTSUS, listed above.
The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading.
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].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division