CLA-2-84:OT:RR:NC:N1:118
Francis Giles
BHS Corrugated North America, Inc.
2431 Bertelkamp Lane
Knoxville, TN 37091
RE: The tariff classification of a pressure belt from Germany
Dear Mr. Giles:
In your letter dated May 7, 2025, you requested a tariff classification ruling on a pressure belt. Technical
information and pictures of the item were submitted with your request.
The pressure belt is constructed of stainless-steel woven wire mesh and will be imported in specific widths,
depending on the customer’s needs. It is used within a corrugating machinery line that produces stacks of
corrugated board from reels of paper. The pressure belt is installed in the module facer, which is the part of
the machinery line that applies the glue to the paper. You have stated that the pressure belt is designed to
work in combination with corrugator rolls. It works by pressing layers of paper together and allows the
bonding needed to create the single face cardboard. This process facilitates the glue adhering to the
cardboard as it travels through the corrugating machinery line.
You suggested classifying the pressure belt within subheading 8439.99.1000, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for machinery for making pulp of fibrous cellulosic material or
for making or finishing paper or paperboard...: parts: other: of machinery for making paper or paperboard.
We disagree. The pressure belt is used within a corrugating line of machinery. Headquarters Ruling
H305598, issued to your company on December 18, 2024, classified this machinery within subheading
8441.80.0000, HTSUS. As the pressure belt is a part used within this machinery, classification within
subheading 8439.99.1000, HTSUS, would be incorrect.
The applicable subheading for the pressure belt will be 8441.90.0000, HTSUS, which provides for other
machinery for making up paper pulp, paper or paperboard, including cutting machines of all kinds, and parts
thereof: parts. The general rate of duty will be Free.
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 8441.90.0000, 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 Anthony Grossi at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division