CLA-2-39:OT:RR:NC:N4:415
Robert A. Martin
Q Holdco, LLC
1700 Highland Road
Twinsburg, OH 44087
RE: The tariff classification of a silicone plastic plug and seal from Mexico.
Dear Mr. Martin:
In your letter dated May 20, 2025, you requested a tariff classification ruling.
Images were provided in lieu of samples. This request consists of two products for consideration.
The first item is described as a “Mini UMNL Cavity Plug Seal,” internal part number 117001. It is a small
plug designed to block off an empty cavity in a Universal MATE-N-LOK (UMNL) electrical connector
where a wire is not being used. It measures 4.1 millimeters in diameter at its widest point and is 7
millimeters long.
The second item is described as a “6P Interface Seal,” internal part number 812018. It is a component used
in six position (6P) electrical connectors and is specifically designed to prevent moisture, dust, and other
contaminants from entering the connection area. It measures 0.8 inches by 0.55 inches.
In your submission you describe these products as being made from silicone rubber and propose they be
classified under heading 4016 as other articles of rubber. Note 4 to Chapter 40, Harmonized Tariff Schedule
of the United States (HTSUS), describes synthetic rubber as applying to unsaturated synthetic substances
which can be irreversibly transformed by vulcanization with sulfur into non-thermoplastic substances which,
at a temperature between 18 and 29 degrees Centigrade, will not break on being extended to three times their
original length and will return, after being extended to twice their original length, within a period of 5
minutes, to a length not greater than 1-1/2 times their original length. Silicone is not unsaturated, and thus, is
not cross-linkable with sulfur. Therefore, silicone is not considered to be rubber for tariff classification
purposes and will be classified under chapter 39 as a plastic.
The applicable subheading for the “6P Interface Seal,” internal part number 812018, will be 3926.90.4590,
HTSUS, which provides for “[o]ther articles of plastics and articles of other materials of headings 3901 to
3914: [o]ther: [g]askets, washers and other seals: [o]ther.” The column one, general rate of duty is 3.5 percent
ad valorem.
As the “Mini UMNL Cavity Plug Seal,” internal part number 117001, would be considered an article of
plastic, and as it is not more specifically provided for elsewhere, the applicable subheading will be
3926.90.9989, HTSUS, which provides for “[o]ther articles of plastics and articles of other materials of
headings 3901 to 3914: [o]ther: [o]ther: [o]ther.” The column one, general rate of duty is 5.3 percent ad
valorem.
Products of Mexico as provided by heading 9903.01.01 in Section XXII, Chapter 99, Subchapter III, U.S.
Note 2(a), HTSUS, other than products classifiable under headings 9903.01.02, 9903.01.03, 9903.01.04, and
9903.01.05, HTSUS, will be subject to an additional 25 percent ad valorem rate of duty. At the time of entry,
you must report the applicable Chapter 99 heading, i.e., 9903.01.01, in addition to subheadings 3926.90.4590
and 3926.90.9989, HTSUS, listed above. Articles that are entered free of duty under the terms of general note
11 to the HTSUS (U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set forth in
subchapter XXIII of Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be subject to the
additional ad valorem duties provided for in heading 9903.01.01. If your product is entered duty free as
originating under the USMCA, you must report heading 9903.01.04, HTSUS, in addition to subheadings
3926.90.4590 and 3926.90.9989, 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., 9903.01.27, in addition to subheadings 3926.90.4590 and 3926.90.9989, 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 CBP Regulations (19 CFR 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 Kristopher Burton at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division