CLA-2-84:OT:RR:NC:N1:104
Deana Smith
The William Carter Company
3438 Peachtree Rd, Suite 1800
Atlanta, GA 30326
RE: The tariff classification of injection type molds from China
Dear Ms. Smith:
In your letter dated May 13, 2025, you requested a tariff classification ruling.
The products at issue are three steel molds which will be used in an injection molding machine for producing
plastic parts. The first mold, W015-176, produces the main body of the plastic Moby baby bathtub, designed
for newborns up to 25 lbs. Its dimensions are 85H x 120L x 90W centimeters. The second mold, W015-177,
forms both the hook and hook attachment for the Moby baby bathtub, which is designed to hang from a
shower curtain rod. Its dimensions are 32H x 35L x 30W centimeters. The third mold, W015-178, produces
the drain plug for the Moby baby bathtub. Its dimensions are 24H x 25L x 22W centimeters.
The applicable subheading for the three steel molds, W015-176, W015-177, and W015-178, will be
8480.71.8045, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Molding
boxes for metal foundry; mold bases; molding patterns; molds for metal (other than ingot molds), metal
carbides, glass, mineral materials, rubber or plastics: Molds for rubber or plastics: Injection or compression
types: Other: Other: Injection type.” The general rate of duty will be 3.1% ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8480.71.8045, 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., 9903.88.01,
in addition to subheading 8480.71.8045, HTSUS, listed above.
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 8480.71.8045, 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 all 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
8480.71.8045, HTSUS, listed above.
In your letter you also request valuation guidance. Appraisement of merchandise is determined by the
commodity team at the port of entry when the item is imported. If you want a valuation determination prior to
that time please send your request with all pertinent information to U.S. Customs and Border Protection,
Office of Rulings and Regulations Valuation and Special Programs Branch, 90 K Street, NE, Washington,
D.C. 20229-1177.
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
(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 Arthur Purcell at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division