CLA-2-65:OT:RR:NC:N1:358
Yvonne Morgan
Supply Chain Solutions
4607 44th St. SE
Grand Rapids, MI 49512
RE: The tariff classification of a helmet and helmet parts from China
Dear Ms. Morgan:
In your letter dated November 13, 2024, you requested a tariff classification ruling on behalf of your client,
Arbill Industries. The sample was submitted for our review and subsequently sent for lab testing.
The submitted sample, identified as a “safety helmet,” is composed of an outer shell of 100% acrylonitrile
butadiene styrene (ABS), and an inner liner of 100% expanded polystyrene (EPS) foam. The helmet has a
suspension insert composed of 85% high-density polyethylene (HDPE), 10% polyformaldehyde (POM), and
5% polyurethane (PU); a sweatband composed of 100% PU; and a chin strap composed of 25% POM, 40%
nylon, 30% PU and 5% ABS. The helmet features a climbing-style design with a 6-point ratchet suspension
system, a breakaway 4-point chin strap and universal accessory slots. In your request, you indicate that the
safety helmet is intended for use as personal protective equipment (PPE) in industrial environments. You also
indicate that the individual components such as the suspension lining, chin strap and sweatband, will be
imported separately.
In order to determine the proper classification, the helmet was submitted to the U.S. Customs and Border
Protection (CBP) laboratory for analysis. The CBP laboratory confirmed that the outer shell is composed of
ABS bonded to an EPS foam liner and determined that the helmet is not reinforced or laminated.
The applicable subheading for the safety helmet will be 6506.10.6075, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for "Other headgear, whether or not lined or trimmed: Safety
headgear: Other… Other: Other.” The general rate of duty will be Free.
The applicable subheading for the suspension lining, chinstrap and sweatband will be 6507.00.0000, HTSUS,
which provides for “Headbands, linings, covers, hat foundations, hat frames, peaks (visor) and chinstraps, for
headgear.” The general rate of duty will be Free.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 6506.10.6075 and 6507.00.0000, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of China, Hong
Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. At the time of entry,
you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition
to subheading 6506.10.6075 and 6507.00.0000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 6506.10.6075, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e. 9903.88.15,
in addition to subheading 6506.10.6075, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 6507.00.0000, HTSUS, unless specifically excluded, are subject to an additional 25 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 6507.00.0000, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
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 Katherine Souffront at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division