CLA-2-85:OT:RR:NC:N1:103
Kurtis Lamberton
Lambertones Pickups
13068 South Ln.
Redlands, CA 92373
RE: The tariff classification of a bar magnet from China
Dear Mr. Lamberton:
In your letter dated April 23, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified as a permanent magnet described as a rectangular bar
composed of aluminum, nickel, and cobalt that measures approximately 2.5 inches in length, 0.5 inches in
width, and 0.1875 inches in thickness. Post importation, the bar magnet is used as a component in an electric
guitar pickup assembly.
In your request, you suggest the permanent magnet is classifiable in heading 9209, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for “Parts (for example, mechanisms for music
boxes) and accessories (for example, cards, discs and rolls for mechanical instruments) of musical
instruments; metronomes, tuning forks and pitch pipes of all kinds.” We disagree. Classification under the
HTSUS is determined in accordance with the General Rules of Interpretation and, in the absence of special
language or context which otherwise requires, by the Additional U.S. Rules of Interpretation. Additional U.S.
Rule of Interpretation 1(c) states that a provision for parts of an article covers products solely or principally
used as a part of such articles but a provision for “parts” or “parts and accessories” shall not prevail over a
specific provision for such part or accessory. In short, we must first consider whether the bar magnet is prima
facie classified in a specific provision. In its imported condition, the permanent bar magnet is described by
the language of heading 8505, HTSUS.
The applicable subheading for the aluminum-nickel-cobalt permanent magnets will be 8505.11.0010,
HTSUS, which provides for “Electromagnets; permanent magnets and articles intended to become permanent
magnets after magnetization; electromagnetic or permanent magnet chucks, clamps and similar holding
devices; electromagnetic couplings, clutches and brakes; electromagnetic lifting heads; parts thereof:
Permanent magnets and articles intended to become permanent magnets after magnetization: Of metal:
Alnico.” The general rate of duty will be 2.1% 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 8505.11.0010, 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 8505.11.0010, 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 Paul Huang at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division