CLA-2-73:OT:RR:NC:N1:164
Winnie Lam
Urban Armor Gear, LLC
1601 Alton Parkway, Suite C
Irvine, CA 92606
RE: The tariff classification of a metal hexagon sticker from China
Dear Ms. Lam:
In your letter dated April 9, 2025, you requested a tariff classification ruling on a metal hexagon sticker from
China. A sample and product information were submitted with your request.
The item under consideration is described as a metal hexagon sticker for use with magnetic mobile phone
accessories. The product enables a user to securely attach their phone (if equipped with a magnetic accessory)
or other magnetic object to a desired surface for hands-free viewing, use, or temporary storage. Although the
product is primarily marketed for use with magnetic phone accessories, it is also described as a
multi-functional magnetic accessory for use in various environments. The metal hexagon sticker is an
equilateral and equiangular hexagon-shaped piece of stainless steel with a black coating. Each side measures
approximately 1.25 inches in length. The distance from side to opposite side is approximately 2.25 inches,
and the distance from angle to opposite angle is approximately 2.5 inches. The hexagon-shaped piece of
stainless steel weighs 30.3 grams.
Affixed to the back surface of the stainless steel hexagon is double-sided ethylene-vinyl acetate (EVA) foam
tape. One side of the tape is permanently attached to the back surface of the hexagon, and the other side
remains exposed and accessible. During use, a removable layer of material is peeled away from the surface of
the tape. Using the exposed adhesive on the surface of the tape, the stainless steel hexagon is placed on a
suitable surface as desired. Once adhered to a surface, the front face of the stainless steel hexagon is exposed
and ready for attachment to a magnetic phone accessory or another magnetic object.
Classification under the Harmonized Tariff Schedule of the United States is in accordance with the General
Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods will be determined according
to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that
the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not
otherwise require, the remaining GRIs 2 through 6 will then be applied in order.
The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official
interpretation of the HTSUS. 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. See T.D. 89-80, 54 Fed. Reg. 35127 (August 23, 1989).
As the metal hexagon sticker is a composite good, we must apply GRI 3(b), which provides that composite
goods are to be classified according to the component that gives the goods their essential character. EN VIII
to GRI 3(b) explains that “the factor which determines essential character will vary as between different
kinds of goods. It may, for example, be determined by the nature of the material or component, its bulk,
quantity, weight or the use of the goods.” We must determine whether the stainless steel or the double-sided
EVA foam tape imparts the essential character to the metal hexagon sticker. In this case, the function of the s
tainless steel hexagon is to provide a modestly sized yet robust metal surface for magnetic objects to attach.
Although the EVA foam double-sided tape allows the stainless steel hexagon to attach to various surfaces for
placement and stability, it does not interact with magnetic objects and thus does not directly accomplish the
primary function of the product. Furthermore, the stainless steel hexagon can used indefinitely, while the
double-sided sticker is a single use item. Finally, you state that the stainless steel hexagon accounts for 92.4%
of the product’s weight (30.3 grams) while the double-sided EVA foam tape accounts for only 7.6% (2.5
grams). In totality, it is the opinion of this office that the stainless steel hexagon imparts the essential
character to the overall product. In accordance with GRI 3(b), the metal hexagon sticker will be classified as
an other article of steel.
The applicable subheading for the metal hexagon sticker will be 7326.90.8688, HTSUS, which provides for
Other articles of iron or steel: Other: Other: Other: Other: Other. The general rate of duty will be 2.9 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 7326.90.8688, 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 7326.90.8688,
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.
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. Your product falls within an
excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.01.33, in addition to subheading 7326.90.8688, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 7326.90.8688, 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 7326.90.8688, 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
(C.F.R.), 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 C.F.R. 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 Paul Taylor at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division