CLA-2-73:OT:RR:NC:N4:422
Mr. Thatcher D. Warick
Woodstream
29 East King Street, Suite 201
Lancaster, PA 17602
RE: The tariff classification of a mousetrap from Vietnam
Dear Mr. Warwick:
In your letter dated April 3, 2025, you requested a tariff classification ruling. Photographs and a user manual
were submitted for review.
The merchandise is the Safe-Set mousetrap, part number M070B. The article consists of a plastic top, a
plastic base, a plastic lever arm, a plastic trigger hood, a plastic bait cup, and a steel-plated zinc torsion spring
wire. The entire mechanism is enclosed in a plastic housing. You have indicated that the mousetrap assists in
the killing of rodents and is designed for household use.
The mousetrap measures approximately 4 inches long by 1 7/8 inches wide by 1 5/8 inches high. In use, the
user opens the bait cup located on the bottom of the trap, and food is placed in the cup. To set the trap, the
user presses down on the top lever arm until it clicks. The trap is now in the open position. The mousetrap is
placed where there are signs of rodent activity. When the mouse enters the trap, the steel-plated zinc torsion
spring wire is activated, which snaps closed when pressure is applied. The trap is then opened to discard the
mouse.
The item is considered a composite good within the meaning of General Rule of Interpretation (GRI) 3. The
mousetrap consists of a plastic top, a plastic base, a plastic lever arm, a plastic trigger hood, a plastic bait
cup, and a steel-plated zinc torsion spring wire. The primary functional component of the mousetrap is the
steel-plated zinc torsion spring wire device, which, when tripped, releases the spring and traps the mouse. It
is the opinion of this office that the steel-plated zinc torsion spring wire imparts the mousetrap’s essential
character. In accordance with GRI 3(b), the mousetrap will be classified in heading 7323.
You propose classification of the Safe-Set mousetrap, part number M070B, in subheading 3926.90.9989,
Harmonized Tariff Schedule of the United States, HTSUS, which provides for which provides for “other
articles of plastics and articles of other materials of headings 3901 to 3914: other: other: other.” We
disagree. The mousetrap is not an article of plastic, but a household article of iron or steel in heading 7323.
Therefore, classification in subheading 3926.90.9989 is precluded.
The applicable subheading for the Safe-Set mousetrap, part number M070B, will be 7323.90.9080, HTSUS,
which provides for “Table, kitchen or other household articles and parts thereof, of iron or steel; Other:
Other: Other: Other. Other.” The rate of duty will be 3.4 percent ad valorem.
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. 9903.01.25, in addition to
subheading 7323, HTSUS, listed above.
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 7323, 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.
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 Dana L. Giammanco at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division