CLA-2-85:OT:RR:NC:N2 209
Patrick Chen
Jiangsu Worldlight New Material Co.,Ltd.
No. 89, Gangzhong Road, Xinbei District
Changzhou 213022
China
RE: The tariff classification of composite frames for photovoltaic (PV) solar panels from China
Dear Mr. Chen:
In your letter dated May 27, 2025, you requested a tariff classification ruling.
The items concerned are composite structural frames used in the manufacture/assembly of photovoltaic (PV)
solar panels.
These particular frames are produced using a pultrusion process that combines continuous glass fibers and
polyurethane resin to form lightweight yet rigid profiles (fiber-reinforced polymer composite frames). The
composite frames serve the same functional purpose as traditional aluminum frames, as they encase or frame
the bare outer edge of the laminated solar panel, providing support and rigidity. They form an integral part of
the finished solar panel/module.
At time of import into the United States, the frames/profiles are cut to size. They consist of two long side
pieces and two shorter top/bottom pieces (actual size depends on the specific model). They incorporate
45-degree mitered cuts at each corner, and have pre-drilled holes and slots.
The applicable subheading for the composite structural solar panel frames (fiber-reinforced polymer
composite frames) will be 8541.90.0000, Harmonized Tariff Schedule of the United States (HTSUS), which
provides for “Semiconductor devices (for example, diodes, transistors, semiconductor-based transducers);
photosensitive semiconductor devices, including photovoltaic cells whether or not assembled in modules or
made up into panels; light-emitting diodes (LED), whether or not assembled with other light-emitting diodes
(LED); mounted piezo-electric crystals; parts thereof.” The general rate of duty will be Free.
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 8541.90.0000, 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. 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. 9903.01.32, in addition to subheading 8541.90.0000, HTSUS, listed above.
Pursuant to U.S. Note 31 (f) to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8541.90.0000, HTSUS, unless specifically excluded, are subject to an additional 50 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.91.05,
in addition to subheading 8541.90.0000, HTSUS, listed above.
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, 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/remedies/301-certain-products-china,
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 Steven Pollichino at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division