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 grommet and seals of silicone plastic from Mexico.

Dear Mr. Martin:

In your letter dated May 21, 2025, you requested a tariff classification ruling.

Images were provided in lieu of samples. This request consists of three products for consideration.

The first item is described as a “6 Way Grommet,” internal part number 211390. It is designed to guide and organize six cables or wires passing through it. The grommet measures 0.606 inches wide by 0.616 inches long by 0.275 inches deep.

The second item is described as a “23 Position Amp Mating Seal,” internal part number 311016. It is a molded gasket that creates a seal to protect electrical connections from dust, water, and other contaminants. The seal measures 41.4 millimeters wide by 21.6 millimeters long by 1.5 millimeters deep.

The third item is described as a “Seal Front 3 Size 16 Contacts DT Series,” internal part number 31132. It serves as an environmental seal for Deutsch DT series electrical connectors. The seal is triangular and measures 0.585 inches at the tallest leg and 0.242 inches deep.

We note that silicone is not considered rubber for tariff classification purposes and instead a plastic of chapter 39.

The applicable subheading for the “23 Position Amp Mating Seal,” and “Seal Front 3 Size 16 Contacts DT Series,” internal part numbers 311016 and 31132, respectively, will be 3926.90.4590, Harmonized Tariff Schedule of the United States (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 “6 Way Grommet,” internal part 211390, 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