CLA-2-40:OT:RR:NC:N5:137
Ryan Hoff
Roxtec Inc.
1140 N 129th E Ave
Tulsa, OK 74116
RE: The tariff classification of low-profile cable entry system from Sweden
Dear Mr. Hoff:
In your letter dated April 17, 2025, you requested a tariff classification ruling.
Item #: CKT0008020016 is described as a low-profile cable entry system. The product consists of a steel
front and back piece that sandwich an injection molded nitrile rubber insert. It also incorporates
ethylene-propylene-non-conjugated diene rubber (EPDM) modules and mounting screws. The product is
designed to seal and protect cables going through walls or enclosures.
Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is in
accordance with the General Rules of Interpretation (GRIs), taken in order. GRI 1 provides that classification
shall be determined according to the terms of the headings and any relative section or chapter notes. Since no
one heading in the tariff schedules covers the stainless steel and plastic components of the couplings in
combination, GRI 1 cannot be used as a basis for classification. GRI 3(b) provides that mixtures, composite
goods consisting of different materials or made up of different components, and goods put up in sets for retail
sale shall be classified as if they consisted of the material or component which gives them their essential
character. As the low-profile cable entry system is a composite good, we must apply rule 3(b), which
provides that composite goods are to be classified according to the component that gives the goods their
essential character.
The Explanatory Notes to the Harmonized Commodity Description and Coding System (ENs), including the
Subheading ENs, although not dispositive or legally binding, provide a commentary on the scope of each
heading of the Harmonized Tariff Schedules, and are generally indicative of the proper interpretation of such
headings. See T.D. 89-80, 54 Fed Reg., 35127 (August 23, 1989). 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 rubber components or the steel components impart the essential
character to the article in question. It is the role of the constituent materials in relation to the use of the good
that imparts the essential character. It is the opinion of this office that the EPDM modules perform the
function of sealing and protecting cables and therefore, impart the essential character of the low-profile cable
entry system.
The applicable subheading for the low-profile cable entry system will be 4016.99.6050, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for other articles of vulcanized rubber other than
hard rubber: other: other: other: other: other: other. The rate of duty will be 2.5 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 Sweden, 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 4016.99.6050, 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 Christina Allen at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division