CLA-2-82:OT:RR:NC:N1:118
Marilyn G. Santos
Supreme International
3000 NW 107th Avenue
Miami, FL 33172
RE: The tariff classification of a bottle opener from China
Dear Ms. Santos:
In your letter dated March 25, 2025, you requested a tariff classification ruling. A sample was provided and
will be retained by our office.
The merchandise under consideration is identified as a Golf Club Bottle Opener, Style OGAFF094. The
bottle opener is in the shape of a decorative mini golf club and measures approximately 7 inches in length. It
can be separated into three pieces for cleaning purposes. You have stated that the item is made of zinc alloy
except for the center handle, which is made of wood.
The applicable subheading for the Golf Club Bottle Opener, Style OGAFF094, will be 8205.51.7500,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for handtools (including glass
cutters) not elsewhere specified or included; blow torches and similar self-contained torches; vises, clamps
and the like, other than accessories for and parts of machine tools; anvils; portable forges; hand- or
pedal-operated grinding wheels with frameworks; base metal parts thereof: other handtools (including glass
cutters) and parts thereof: household tools, and parts thereof: other. The general rate of duty will be 3.7% 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 8205.51.7500, 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 8205.51.7500, HTSUS, listed above.?
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8205.51.7500, 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 8205.51.7500, HTSUS, listed above.
You also inquired whether the Section 232 additional duties on certain derivative aluminum products applies
to the Golf Club Bottle Opener, Style OGAFF094. ?Articles of subheading 8205.51.7500, HTSUS, are not
among those listed in Annex 1 to Presidential Proclamation 10895.
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 Anthony Grossi at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division