CLA-2-94:OT:RR:NC:N5:130
Mr. John Hanson
MBC Brokers, Inc.
13823 Judah Ave.
Hawthorne, CA 90250-6415
RE: The tariff classification of steel storage units from Turkey
Dear Mr. Hanson:
In your letter, dated April 10, 2025, you requested a binding tariff classification ruling on behalf of your
client, Flat Pack Container. The ruling was requested on steel storage units. Product information and photos
were submitted for our review.
The product under consideration is flat-pack, container-style storage units. The units are made of steel and
have four walls, a roof, and a floor. Each unit has at least one door for entry by a human to store goods
inside. The units are shipped flat and assemble easily within 30 minutes. They are imported in multiple styles
and colors. The storage units are built to withstand the elements and are empty inside with no shelves or
fixtures. The units are movable by forklift, but are designed to remain generally in one location, not for use in
the conveyance of goods.
A storage unit – effectively a shed – meets the definition of a “prefabricated building” as set forth in Note 4
to Chapter 96 of the Harmonized Tariff Schedule of the United States (HTSUS):
For the purposes of heading 9406, the expression "prefabricated buildings" means buildings which are
finished in the factory or put up as elements, entered together, to be assembled on site, such as
housing or worksite accommodation, offices, schools, shops, sheds, garages or similar buildings
The instant units are finished in the factory and entered to be assembled on site to function as a storage shed.
The applicable subheading for the storage units will be 9406.90.0130, HTSUS, which provides for
Prefabricated buildings: Other: Of metal: Other. The rate of duty will be 2.9 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, including Turkey, 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 9406.90.0130, HTSUS, listed above.
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 Laurel Duvall at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division