CLA-2-68:OT:RR:NC:N1:128
9903.01.24, 9903.01.25, 9903.88.03
Mr. Howard Yang
CeramSource, Inc.
400 Enterprise Dr, Suite 104
Beaver Falls, PA 15010
RE: The tariff classification of three ceramic fiber products and two ceramic bricks from China.
Dear Mr. Yang:
In your letter dated May 8, 2025, you requested a tariff classification ruling.
The merchandise under consideration is five items identified as TaoFibre Ceramic Fiber Blanket, TaoFibre
Ceramic Fiber Paper, TaoFibre Ceramic Fiber Board, Refractory High Alumina Bricks, and Insulating Fire
Bricks. Samples were submitted with your ruling request and were forwarded to the Customs and Border
Protection Laboratory for analysis. This analysis has been completed.
The TaoFibre Ceramic Fiber Blanket is a needled mat measuring 12.5 feet, 17 feet or 25 feet long, either 24
inches (61 centimeters) or 48 inches (122 centimeters) wide, and in thicknesses ranging from 0.25 inches to 2
inches. It is imported in either rolls or batts, and is designed for use as furnace linings, kiln insulation, and
pipe wrapping. Laboratory analysis has determined that the Ceramic Fiber Blanket is comprised of ceramic
fiber.
The TaoFibre Ceramic Fiber Paper is a flexible sheet with dense multiple layers, imported in roll form. It
ranges from 25 feet long to 400 feet long, is either 24 inches or 48 inches in width, and ranges from 0.03
inches to 0.25 inches in thickness. You state that it is used in gasketing, wrapping for expansion joints, and
thermal barriers. Laboratory analysis has determined that the Ceramic Fiber Paper is comprised of ceramic
fiber.
The TaoFibre Ceramic Fiber Board is an individual, rigid insulation board measuring 24 inches long by 36
inches wide, 24 inches long by 48 inches wide, or 42 inches long by 48 inches wide, and in thicknesses
ranging from 0.25 inches to 2 inches. You state that this board is designed for use as heat shields, in furnace
doors, and in combustion chambers. Laboratory analysis has determined that the Ceramic Fiber Board is
comprised of ceramic fiber.
The Refractory High Alumina Brick we received is rectangular, white in color and very porous in
appearance. It measures approximately 11.4 centimeters long by 22.9 centimeters wide by 7.5 centimeters
thick at its widest points. Laboratory analysis has determined that it is made of refractory ceramic composed
primarily of mullite and alumina. You state that this brick is used in furnaces, steelmaking, cement kilns, and
incinerators, and its normal operating temperature ranges from 1400° Celsius to 1600° Celsius.
The Insulating Fire Brick we received is a mottled tan in color and measures approximately 11 centimters
long by 22.9 centimeters wide by 9.2 centimeters thick at its widest points. The top and bottom sides of the
bricks each feature three trapezoidal cut-outs. Laboratory analysis has determined that it is made of
non-porcelain, non-china ceramic. You state that this brick is used as insulation in kilns and forges, and its
normal operating temperature ranges from 1200° Celsius to 1400° Celsius.
In your ruling request you suggest classification of the TaoFibre Ceramic Fiber Blanket, TaoFibre Ceramic
Fiber Paper, TaoFibre Ceramic Fiber Board, Refractory High Alumina Bricks, and Insulating Fire Bricks in
2818.20.00, Harmonized Tariff Schedule of the United States (HTSUS), as aluminum oxide other than
artificial corundum. However, Chapter 28, HTSUS, provides for separate chemically defined elements and
separate chemically defined compounds, with limited permissible additions. Pursuant to Note 1 to Chapter
28, because the aluminum oxide is mixed with various other substances, it is precluded from classification
within this chapter.
You also suggest classification of the Insulating Fire Brick as a refractory ceramic. However, refractory
ceramics must not only meet the Chapter 69 Additional U.S. Note definition of refractory ceramic, they must
also be used in a high-temperature environment of at least 1500° Celsius. As the normal operating
temperature of the Insulating Fire Brick is below 1500° Celsius, classification as a refractory ceramic is
precluded.
The applicable subheading for the TaoFibre Ceramic Fiber Blanket, when imported in batt form and in
widths of 24 inches, will be 6806.10.0020, HTSUS, which provides for “Slag wool, rock wool and similar
mineral wools; exfoliated vermiculite, expanded clays, foamed slag and similar expanded mineral materials;
mixtures and articles of heat-insulating, sound-insulating or sound-absorbing mineral materials…: Slag
wool, rock wool, and similar mineral wools (including intermixtures thereof), in bulk, sheets, or rolls:
Other: Batts, not exceeding 61 cm in width.” The general rate of duty will be 3.9 percent ad valorem.
The applicable subheading for the TaoFibre Ceramic Fiber Blanket, when imported in batt form and in
widths of 48 inches, will be 6806.10.0040, HTSUS, which provides for “Slag wool, rock wool and similar
mineral wools; exfoliated vermiculite, expanded clays, foamed slag and similar expanded mineral materials;
mixtures and articles of heat-insulating, sound-insulating or sound-absorbing mineral materials…: Slag wool,
rock wool, and similar mineral wools (including intermixtures thereof), in bulk, sheets, or rolls: Other:
Batts, exceeding 61 cm in width.” The general rate of duty will be 3.9 percent ad valorem.
The applicable subheading for the TaoFibre Ceramic Fiber Blanket, when imported in roll form, will be
6806.10.0090, HTSUS, which provides for “Slag wool, rock wool and similar mineral wools; exfoliated
vermiculite, expanded clays, foamed slag and similar expanded mineral materials; mixtures and articles of
heat-insulating, sound-insulating or sound-absorbing mineral materials…: Slag wool, rock wool, and similar
mineral wools (including intermixtures thereof), in bulk, sheets, or rolls: Other: Other.” The general rate of
duty will be 3.9 percent ad valorem.
The applicable subheading for the TaoFibre Ceramic Fiber Paper will be 6806.10.0090, HTSUS, which
provides for “Slag wool, rock wool and similar mineral wools; exfoliated vermiculite, expanded clays,
foamed slag and similar expanded mineral materials; mixtures and articles of heat-insulating,
sound-insulating or sound-absorbing mineral materials…: Slag wool, rock wool, and similar mineral wools
(including intermixtures thereof), in bulk, sheets, or rolls: Other: Other.” The general rate of duty will be
3.9 percent ad valorem.
The applicable subheading for the TaoFibre Ceramic Fiber Board will be 6806.90.0090, HTSUS, which
provides for “Slag wool, rock wool and similar mineral wools; exfoliated vermiculite, expanded clays,
foamed slag and similar expanded mineral materials; mixtures and articles of heat-insulating,
sound-insulating or sound-absorbing mineral materials…: Other: Other: Other.” The general rate of duty
will be Free.
The applicable subheading for the Refractory High Alumina Brick will be 6902.20.1010, HTSUS, which
provides for “Refractory bricks, blocks, tiles and similar refractory ceramic constructional goods, other than
those of siliceous fossil meals or similar siliceous earths: Containing by weight more than 50 percent of
alumina (Al2O3), of silica (SiO2) or of a mixture or compound of these products: Bricks: Alumina.” The
general rate of duty will be Free.
The applicable subheading for the Insulating Fire Brick will be 6914.90.8000, HTSUS, which provides for
“Other ceramic articles: Other: Other.” The general rate of duty will be 5.6 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 subheadings 6806.10.0020, 6806.10.0040, 6806.10.0090, 6806.90.0090, 6902.20.1010, and 6914.90.8000,
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. At this time products from China 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 subheadings
6806.10.0020, 6806.10.0040, 6806.10.0090, 6806.90.0090, 6902.20.1010, and 6914.90.8000, HTSUS, listed
above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 6806.10.0020, 6806.10.0040, 6806.10.0090, 6806.90.0090, 6902.20.1010, and 6914.90.8000,
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 subheadings
6806.10.0020, 6806.10.0040, 6806.10.0090, 6806.90.0090, 6902.20.1010, and 6914.90.8000, 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/.
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 Nicole Sullivan at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division