CLA-2-83:OT:RR:NC:N5:121
Yolanda Lau
Eagle Resources Trading Ltd.
15/F, Yinlong Building
Xiamen
China
RE: The tariff classification of iron wreath hangers from China
Dear Ms. Lau:
In your letter dated March 19, 2025, you requested a tariff classification ruling.
The merchandise under consideration is described as a “Wreath Hanger with decorative icon”. These iron
metal hangers have an over-the-door hook on top and a rounded hook on the bottom that can be used to hang
wreaths or other items. There are 5 different groups of hangers. The first 4 groups of hangers are decorated
with an iron metal icon near the top and measure approximately 12.5-inches long, 1-inch wide, and fit doors
up to 2-inches thick. Item number 324-Z53102 features four different designs on white hangers depicting an
Easter theme: 2 carrots with the words “Hop On In!”, a decorated egg with the words “Happy Easter”, a
bunny head and front paws, and a bunny tail and back paws. Item number 324-8120 features 4 different
designs depicting an autumn theme: 3 mushrooms with leaves on a red hanger, 3 sunflowers with leaves on a
yellow hanger, an autumn wreath encircling the words “Autumn is Calling” on a maroon hanger, and 4
gourds and leaves on a green hanger. Item number 324-6921 features 2 different designs depicting a
Christmas theme: a red reindeer on a white hanger, and a red plaque with the words “Merry Christmas” on a
green hanger. Item number 324-Z58400 features 4 different designs on black hangers depicting a Halloween
theme: a skeleton hand, a smiling ghost, 2 large green eyes, and 3 bats. The 5th group of hangers measures
approximately 13-inches long, 1-inch wide, and fits doors up to 2-inches thick. Item number 324-F50126B
features 2 designs: a gold hanger with 3 gold jingle bells near the top, and a silver hanger with 3 silver jingle
bells near the top.
You suggest these hangers may be classifiable in 8306.29.0000, Harmonized Tariff Schedule of the United
States, (HTSUS) which provides for Bells, gongs and the like, nonelectric, of base metal; statuettes and other
ornaments, of base metal; …: Statuettes and other ornaments, and parts thereof: Other. We disagree.
The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official
interpretation of the Harmonized System at the international level. While not legally binding nor dispositive,
the ENs provide a commentary on the scope of each heading of the HTSUS and are generally indicative of
the proper interpretation of these headings. As per the ENs, heading 8306 states, “It should be noted that the
group does not include articles of more specific headings of the Nomenclature, even if those articles are
suited by their nature or finish as ornaments.” It is our opinion that this vertically mounted iron metal hook
that functions to hang a wreath is more specifically described by the subheading language of 8302.50.0000,
HTSUS.
The applicable subheading for the “Wreath Hanger with decorative icon” item numbers 324-Z53102,
324-8120, 324-6921, 324-Z58400, and 324-F50126B will be 8302.50.0000, HTSUS, which provides for
Base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds,
coachwork, saddlery, trunks, chests, caskets or the like; base metal hat racks, hat-pegs, brackets and similar
fixtures; …: Hat-racks, hat pegs, brackets and similar fixtures, and parts thereof. The 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 8302.50.0000, 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. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other
countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must
report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.63, in addition to
subheading 8302.50.0000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8302.50.0000, 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 8302.50.0000, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively.
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 Jennifer Jameson at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division