CLA-2-76:OT:RR:NC:N5:116
Mr. Dominic Menzel
Deha Design LLC
1900 W. Loop South, Suite 1550
Houston, Texas 77027
RE: The tariff classification of aluminum profiles from Germany
Dear Mr. Menzel:
In your letter dated May 7, 2025, you requested a tariff classification ruling.
The products under consideration are described as aluminum “mouldings” for use in the manufacture of
picture and art frames. These profiles, which are made from type 6063 and 6463 aluminum alloy, have been
extruded, anodized, lacquered, brushed, etc. and will be imported in 10- foot lengths.
You suggested these articles may be classifiable in 8306.30.0000, Harmonized Tariff Schedule of the United
States (HTSUS), which provides for Photograph, picture or similar frames; mirrors; and parts thereof. We
disagree. At the time of importation, the products in question are extruded profiles (extrusions) measuring 10
feet in length. They are imported without glass or backing materials, and they are sold without hardware.
These profiles are not finished frames, nor are they identifiable as frames at the time of importation, therefore
they cannot be classified as frames of 8306.30.0000, HTSUS. The subject items have no enclosed void (open
construction). For tariff purposes, these products are considered to be other profiles and are more specifically
provided for in another subheading of the HTSUS.
The applicable subheading for the aluminum profiles will be 7604.29.1010, HTSUS, which provides for
aluminum bars, rods and profiles: of aluminum alloys: other: other profiles: heat-treatable industrial alloys of
a kind described in statistical note 7 to this chapter. The rate of duty will be 5 percent ad valorem.
On March 12, 2025, Presidential proclamations 10895 and 10896 imposed additional tariffs on products of
steel and aluminum. Additional duties for steel and aluminum products of 25 percent are reflected in Chapter
99, heading 9903.81.87 for steel and heading 9903.85.02 for aluminum. Products classified under subheading
7604.29.1010, HTSUS, may be subject to additional duties. At the time of entry, you must report the Chapter
99 heading applicable to your product classification, i.e. 9903.85.02, in addition to the Chapter 72, 73 or 76
subheadings listed above. Please note that 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 9903.81.88, 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 7604.29.1010, HTSUS, listed above.
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/current.
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 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, contact
National Import Specialist Angelia Amerson at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division