CLA-2-39:OT:RR:NC:N1:137
Paul F. Fitzpatrick
OMF Associates
131R Derby Street
Salem, Massachusetts 01970
RE: The tariff classification of dishwasher installation kit from Taiwan
Dear Mr. Fitzpatrick:
In your letter dated August 13, 2020 you requested a tariff classification ruling on behalf of your client, EZ-FLO International, Inc.
The products under consideration are dishwasher installation kits, model numbers 41150 and 48337N. Both kits include a 6’ water supply line consisting of a core hose of polyvinyl chloride (PVC) and outer stainless steel braided hose with fittings, brass nuts,a stainless steel hose clamp, a Romex connector, Teflon tape, and plastic wire nuts. Model 41150 contains a straight power cord and model 48337N contains a power cord with a 90-degree angle.
The Explanatory Notes to the Harmonized Tariff System provide guidance in the interpretation of the Harmonized Commodity Description and Coding System at the international level. Explanatory Note X to GRI 3(b) provides that the term "goods put up in sets for retail sale" means goods that: (a) consist of at least two 2 different articles which are, prima facie, classifiable in different headings; (b) consist of articles put up together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without repacking. Goods classifiable under GRI 3(b) are classified as if they consisted of the material or component which gives them their essential character, which may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the article. This office considers each installation kit to be a set for tariff classification purposes, with the essential character imparted by the 6’ water supply line.
The applicable subheading for the dishwasher installation kits will be 3917.39.0010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for tubes, pipes and hoses and fittings therefor (for example, joints, elbows, flanges), of plastics: other tubes, pipes and hoses: other: reinforced with metal. The general rate of duty will be 3.1 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 the 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, contact National Import Specialist Christina Allen at julie.c.allen.cbp.dhs.gov.
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division