CLA-2-73:OT:RR:NC:N1:164
Jacqui Lawhead
Boise Cascade
1111 W. Jefferson St., Suite 300
Boise, ID 83702
RE: The tariff classification of steel plywood clips and steel base brackets from China
Dear Ms. Lawhead:
In your letter dated May 5, 2025, you requested a tariff classification ruling regarding the classification of
steel plywood clips and steel base brackets from China. Descriptive literature and digital photographs were
submitted with your request.
The first items under consideration are described as steel plywood clips of various sizes. Based on the
submitted information, the plywood clips are pieces of steel which are first bent to a “U” shape. From the
side walls, sections of steel are punched to shape and bent downward to form a parallel “U” in the opposite
direction. When in use, the clips are designed to provide a gap between the horizontal edges of adjacent
sheets of plywood. The clips are 100 percent steel with a galvanized zinc finish. You state that the width,
depth and height of all versions are less than 2 inches.
The second items under consideration are described as steel base brackets to be imported in two sizes. The
base brackets consist of a U-shaped section of steel with a threaded steel rod which extends below. When
installed, the U-shaped bracket is fastened to a wooden post above, and the threaded rod is fastened with a
nut and washer into a base material beneath. Functionally the base brackets form a secure connection to hold,
support, and connect a wooden post to a base in various applications. The threaded rod component also
allows for vertical adjustment of the connected post. The base brackets are 100 percent steel with a
galvanized zinc finish. You state that one version is designed to hold 4 by 4 inch posts, and the other is
designed to hold 6 by 6 inch posts.
In your request, you suggest classification of the steel plywood clips and steel base brackets in subheading
8302.41.6080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Base metal
mountings, fittings and similar articles . . . Other mountings, fittings, and similar articles, and parts thereof:
Suitable for buildings: Other: Of iron or steel, of aluminum or of zinc . . . Other. We disagree. Heading 8302,
HTSUS, provides for base metal mountings, fittings and similar articles suitable for furniture, doors,
staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like. Plywood and posts are
not of the same class or kind as the exemplars of heading 8302. Consequently, the plywood clips and base
brackets are precluded from classification in heading 8302, HTSUS.
Heading 7326 covers a wide range of iron or steel articles that are not more specifically provided for
elsewhere in the tariff. Noting that the plywood clips and base brackets are not more specifically provided for
in heading 8302 or in any other heading of the tariff, the subject items will be classifiable under heading
7326, which provides for other articles of iron or steel.
The applicable subheading for the steel plywood clips 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.
The applicable subheading for the steel base brackets 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.
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. At this time products from all 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.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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,
(for)
Steven A. Mack
Director
National Commodity Specialist Division