CLA-2-42:OT:RR:NC:N3:354
R. Williams
Clark Hill PLC
130 E. Randolph Street, Suite 3900
Chicago, IL 60601
RE: The tariff classification of gloves from Australia
Dear Mr. Williams:
In your letter dated April 13, 2025, you requested a tariff classification ruling on behalf of your client, The
Glove Company. The sample will be retained.
Model PV800 is a Personal Voltage Alert Device (PVAD) glove. The glove is constructed with a palm side
of cow leather and a backside of polyvinyl chloride and neoprene. The glove features leather fourchettes,
palm reinforcement patches, a backside lining and an elastic wrist. You state that this glove is designed as a
safety device to warn the user of live electrical voltage. The back side of the glove is stated to have a
microprocessor, a battery, and an audio alert device. The essential character of the glove is imparted by the
palm side cowhide leather.
You proposed classification within heading 8531, Harmonized Tariff Schedule of the United States
(HTSUS). Heading 8531, HTSUS, which provides, in relevant part, for “Electric sound or visual signaling
apparatus … other than those of heading 8512 or 8530.” It covers products which function to provide a
visual and/or audible signal to the user. Such devices must have the ability to issue a sound or visual
alert/indication that is readily understood by the user.
The item concerned is a work/safety glove and is used to provide protection for the user. The addition of the
electrical current/voltage signaling device provides an additional level of protection, which we view as an
enhancement to the glove. The electrical elements within the glove provide a support or secondary
function. If the electrical components fail, it can still function as a normal work glove. We believe the
principal use of the item is that of a work glove, which provides comfort, protection and gripping properties
to the user. As such, based on the use and function of the item concerned, classification within heading 8531,
HTSUS, would be inapplicable.
The applicable subheading for the glove will be 4203.29.1500, HTSUS, which provides for ?Articles of
apparel and clothing accessories, of leather or of composition leather: Gloves, mittens and mitts: Other:
Gloves of horsehide or cowhide (except calfskin) leather: Other: With fourchettes or sidewalls which, at a
minimum, extend from fingertip to fingertip between each of the four fingers. The rate of duty will be 14
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 4203.29.1500, 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 Karen Sikorski at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division