CLA-2-84:OT:RR:NC:N1:104
TARIFF NOS.: 8479.90.8500; 9903.88.15; 9903.01.24; 9903.85.08
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 4, 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 for original equipment
purposes. The items are specially shaped and designed for use only with the Bigbelly bins.
Part No. MTLBB60002 is a rectangular shaped, galvanized steel rear panel. The rear panel measures
approximately 44 (H) x 23 (W) inches. The panel covers the back side of the Bigbelly bins and provides
structural support to the bin’s enclosure.
Part No. MTLBB60003 is a galvanized steel top panel/plate. This rectangular-shaped item separates the
actual waste/recycling material from the solar cell compartment and provides structural support to the bins.
The top panel measures approximately 23 (L) x 24 (W) inches and has several unique cutouts.
Part No. MTLBB60006 is a galvanized steel cover side channel. This item measures approximately 44 (L) x
9 (W) inches and provides structural integrity to the Bigbelly unit in addition to separating the main cabinet
from the compactor’s moving parts.
Part No. MTLBB60007 is a galvanized steel throat. This item is mainly flat and rectangular in shape but has
a unique curvature near its center middle to fit into the Bigbelly bins. The throat provides a barrier between
the main cabinet and compactor, protecting the user from the compactor mechanism.
Part No. MTLB600020 is the idler sprocket cover. This galvanized steel cover provides the pivot point for
the sprockets that engage the compactor and is also a load-bearing structural element.
The applicable subheading for all five items, i.e., Part Nos. MTLBB60002, MTLBB60003, MTLBB60006,
MTLBB60007, and MTLB600020, imported individually, will be 8479.90.8500, Harmonized Tariff
Schedule of the United States (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 rate of duty will be free.
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 subheading 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 regarding the ruling, please contact
National Import Specialist Arthur Purcell at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division