CLA-2-84:OT:RR:NC:N1:104
TARIFF NOS.: 8479.90.8500; 7312.10.5000; 9903.01.24; 9903.81.91; 9903.81.93; 9903.85.08; 9903.88.03;
9903.88.15
David Robeson
Mohawk Global
123 Air Cargo Road
Syracuse, NY 13212
RE: The tariff classification of components for trash compactor bins from China
Dear Mr. Robeson:
In your letter dated March 3, 2025, on behalf of your client, Prismier, you requested a tariff classification
ruling.
The products in question are five (5) components for the cabinets of “smart” waste disposal and recycling
bins, referred to as the Bigbelly Sense Max and Bigbelly Smart Max bins (collectively, “Bigbelly bins”). The
Bigbelly bins, which are not imported with the subject components, function as waste and/or recycling
receptacles and are equipped with a sensor-activated, automatic compacting function. The bins are fully
enclosed and will be situated in public places. Each of the five items will be imported individually for
original equipment purposes.
Part No. MSPBB60008 is a stainless-steel front door release cable. This cable is 24 inches in length and has a
diameter of 0.047 inch. Each end of the cable is fitted with stainless steel split rings. You state that the cable
is configured for the Bigbelly bins but could be used in other applications.
The remaining items are specially shaped and designed for use solely with the Bigbelly bins.
Part No. MTLBB50137 is an aluminum foot pedal to open the chute for waste disposal or collection for
recycling. The foot pedal measures approximately 17 (W) x 5 (D) inches.
Part No. MTLBB60008 is a front door panel stamped out of galvannealed steel. This rectangular panel is the
front enclosure of the Bigbelly bins. The panel has a cutout for the chute near the top of the bin and a foot
pedal area near the bottom of the panel.
Part No. MTLBB60034 is a front door rain gutter that is stamped out of stainless steel. This item provides a
water ingress feature to direct rain away from selective areas. It measures approximately 20 (L) x 1 (W)
inches with raised ends.
Part No. MTLBB60041, the front door latch access plate, is a galvanized steel panel that prevents public
access to the door lock hardware. The plate has an irregular shape and is custom designed to fit over the
locking area.
The applicable subheading for the Door Release Cable will be 7312.10.5000, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for “Stranded wire, ropes, cables, plaited bands, slings and the
like, of iron or steel, not electrically insulated: Stranded wire, ropes and cables: Stranded wire: Of stainless
steel: Fitted with fittings or made up into articles.” The general rate of duty will be free.
The applicable subheading for the remaining four items, i.e., Part Nos. MTLBB50137, MTLBB60008,
MTLBB60034, and MTLBB60041, imported individually, will be 8479.90.8500, HTSUS, which provides
for “Machines and mechanical appliances having individual functions, not specified or included elsewhere in
this chapter; parts thereof: Parts: Of trash compactors: Other.” The general rate of duty will be free.
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 25 percent are reflected in Chapter
99, headings 9903.81.89 and 9903.81.90. Products provided by heading 9903.81.91 will be subject to a duty
of 25 percent upon the value of the steel content. At the time of entry, you must report the Chapter 99
heading applicable to your product classification, i.e. 9903.81.90, in addition to subheading 7312.10.5000,
HTSUS. Derivative iron or steel products processed in another country from steel articles melted and poured
in the United States, provided for in heading 9903.81.92, are not subject to the additional ad valorem duties.
Please note that derivative steel products admitted to a U.S. foreign trade zone under “privileged foreign
status” before March 12, 2025, and entered for consumption on or after March 12, 2025, may be subject to
additional duties under heading 9903.81.93, HTSUS.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 7312.10.5000, 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 7312.10.5000, HTSUS, listed above.
Products of China classified under subheading 8479.90.8500, HTSUS, unless specifically excluded, are
subject to the 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 8479.90.8500, HTSUS, listed above.
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 subheadings 7312.10.5000 and 8479.90.8500, HTSUS, listed above.
On March 12, 2025, Presidential proclamation 10895 imposed additional tariffs on certain derivative
aluminum products. Additional duties for derivative aluminum products of 25 percent are reflected in
Chapter 99, headings 9903.85.04 and 9903.85.07. Products provided by heading 9903.85.08 will be subject
to a duty of 25 percent upon the value of the aluminum content. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.85.08, in addition to subheading
8479.90.8500, HTSUS. Derivative aluminum articles processed in another country from aluminum articles
that were smelted and cast in the United States, provided for in heading 9903.85.09, are not subject to the
additional ad valorem duties.
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 the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. If 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 concerning subheading
7312.10.5000, please contact National Import Specialist Denise Hopkins at [email protected]. For
questions concerning subheading 8479.90.8500, please contact National Import Specialist Arthur Purcell at
[email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division