CLA-2-39:OT:RR:NC:N5: 137
Cheryl Wynn
Dollar General CDR
100 Mission Ridge
Goodlettsville, TN 37072
RE: The tariff classification of wall hooks from China
Dear Ms. Wynn:
In your letter dated March 31, 2025, you requested a tariff classification ruling. A photo of the product was
submitted with your request.
The product under consideration is referred to as Clear Mini Hooks (SKU#: 40574301). The blister package
contains 12 clear plastic hooks and 12 adhesive strips with release backing. The adhesive strips are first
attached to the hook and then attached to a wall to hold various items.
You propose classification of removable clear plastic hooks in subheading 3924.90.5650, Harmonized Tariff
Schedule of the United States (HTSUS). We disagree. The Explanatory Notes for heading 39.24 (D) covers
the following articles of plastics: (D) Hygienic and toilet articles (whether for domestic or non-domestic use)
such as toilet sets (ewers, bowls, etc.), sanitary pails, bed pans, urinals, chamber-pots, spittoons, douche cans,
eye baths; teats for baby bottles (nursing nipples) and finger-stalls; soap dishes, towel rails, tooth-brush
holders, toilet paper holders, towel hooks and similar articles for bathrooms, toilets, or kitchens, not intended
for permanent installation in or on walls. However, such articles intended for permanent installation in or on
walls or other parts of buildings (e.g., by screws, nails, bolts, or adhesives) are excluded (heading 39.25).
Therefore, classification of these three items in heading 3924, HTSUS, is precluded.
The applicable subheading for the wall hooks will be 3925.90.0000, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for builders’ ware of plastics, not elsewhere specified or included:
other. The rate of duty will be 5.3 percent ad valorem.
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 3925.90.0000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 3925.90.0000, 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 3925.90.0000, 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 Christina Allen at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division