CLA-2-87:OT:RR:NC:N2:206
Daniel Radoslav
Westhill Innovation Inc.
620 Ireland Road
Simcoe, Ontario N3Y 4K2
Canada
RE: The tariff classification of composite swing doors and side walls from Canada
Dear Mr. Radoslav:
In your letter dated October 09, 2018, you requested a tariff classification ruling. Descriptive literature and pictures were provided with your request.
The items under consideration have been identified as a PlateDoor and PlateWall, which are composite panels used in trailers. The PlateDoor, which you refer to as Composite Swing Door is composed of G90 galvanized Grade 80 steel or aluminum, and pre-painted with a polyester based paint. Its core is made of 100% recycled materials. It measures 0.508 inches (4.3 inches maximum) in thickness, 48 inches (54 inches maximum) in width and 110 inches (144 inches) in length.
The PlateWall, which you refer to as a Composite Side Wall is composed of G90 galvanized Grade 80 steel pre-painted or aluminum, and pre-painted with a polyester based paint. Its core is made from 100% recycled materials. It measures 0.272 inches (4.3 inches maximum) in thickness, 48 inches (54 inches maximum) in width and 110 inches (144 inches maximum) on length.
You state in your letter that the panels are imported ready for intended use as side walls and doors in a truck trailer. They are typically installed with adhesive bonding or mechanical fastening end-to-end. In some cases, the panels are punched and riveted, depending on the user preference.
You suggested classifying the steel panels in heading 7326, Harmonized Tariff Schedule of the United States (HTSUS), as articles of steel, and aluminum panels in heading 7616, HTSUS, as articles of aluminum.
Heading 7326, HTSUS, provides for a wide range of articles made of iron or steel that are not more specifically provided for elsewhere/in any other heading of the tariff. Similarly, heading 7616, HTSUS, provides for a wide range of articles made of aluminum that are not more specifically provided for elsewhere/in any other heading of the tariff.
Based on the pictures of the panels in their imported condition, they appear to be structural parts, such as walls and doors, of truck trailers. Therefore, the subject products would not be classified under heading 7326 or 7616, HTSUS, which provides for other articles of iron or steel, or other articles of aluminum, respectively, because they are more specifically covered elsewhere in another heading in the tariff.
The applicable subheading for the PlateDoor and PlateWall will be 8716.90.5060, which provides for “Trailers and semi-trailers; other vehicles, not mechanically propelled; and parts thereof: Parts: Other: Other.” The general rate of duty will be 3.1% 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.
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, please contact National Import Specialist Liana Alvarez at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division