CLA-2-83:OT:RR:NC:N5:121
Clifford Cheng
CVH Company Limited
Rm 1201-1202, 12/F, Telford House, Kowloon Bay
Hong Kong
China
RE: The tariff classification of iron wreath hangers from China
Dear Mr. Cheng:
In your letter dated March 20, 2025, you requested a tariff classification ruling.
The merchandise under consideration is described as iron Christmas wreath hangers. These 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. Item K090161 is a silver hanger with a decorative silver snowflake design in the center. Item
K090219 is a bronze hanger with a decorative bronze reindeer design in the center. Item K310238 is a black
hanger with a square MDF sign in the center featuring a black and white checkered pattern and the words
“Merry Christmas”. Item K310723 is a red hanger with a decorative MDF sign in the center that features the
words “Jesus is the Reason for the Season”. Item X761138 is a brown hanger with a decorative MDF sign
shaped like a Christmas tree in the center that features a cardinal, snowflakes, the word “Peace” and includes
pine needles and 2 pinecones. Items K090161, K090219, K310238, and K310723 measure approximately
14.5 inches long. Item X761138 measures approximately 15 inches long.
The applicable subheading for the iron Christmas wreath hangers item numbers K090161, K090219,
K310238, K310723, and X761138 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.
In response to your specific question, articles made of iron that are classified under subheading
8302.50.0000, HTSUS, are not currently subject to the application of the Section 232 tariffs for derivative
products or steel or aluminum that are currently in place.
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