CLA-2-76:OT:RR:NC:N:422
Mr. Ted Kim
Express Customhouse Broker, Inc.
1010 Northern Blvd, Ste 330
Great Neck, NY 11021
RE: The tariff classification of a fire pit from China
Dear Ms. Kim:
In your letter dated May 27, 2025, on behalf of your client, Packfire, Inc., you requested a tariff classification
ruling. Photographs, a diagram, and a product information sheet were submitted with your request.
The item is a portable fire pit, Model No. 10125001. The wood-fueled outdoor fire pit is to be placed on the
ground and is collapsible. The item includes a spark screen, tools, a user’s manual, and a carrying backpack.
All items are imported and packaged together for retail sale. The portable fire pit consists of a steel top ring.
The inside body of the fire pit is made of steel. The base pan, ashpan, and legs are stainless steel. The outer
body of the fire pit is made of aluminum. The round fire pit, when fully assembled, measures approximately
22.4 inches high and has a diameter of 17 inches. The rim width is 3 inches. The fire pit weighs 27.5 lbs. The
item is intended for outdoor residential backyard use and campsites.
Pursuant to GRI 1, a fire pit is classified according to the constituent material of its outer body. Please see
Headquarters ruling H306789 dated July 12, 2021. Since the outer body of the portable fire pit is made of
aluminum, the article will be classified in heading 7615, which provides for table, kitchen or other household
articles and parts thereof, of aluminum.
The applicable subheading for the portable fire pit, Model No. 10125001, will be 7615.10.9100, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for “Table, kitchen or other household articles
and parts thereof, of aluminum: Other: Other.” The rate of duty will be 3.1 percent ad valorem.
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.
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 7615.10.9100, HTSUS, listed above.
On March 12, 2025, Presidential proclamation 10895 imposed additional tariffs on certain derivative
aluminum products. Additional duties for derivative aluminum products of 50 percent are reflected in
Chapter 99, headings 9903.85.04 and 9903.85.07. Products provided by heading 9903.85.08 will be subject
to a duty of 50 percent upon the value of the aluminum content. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.85.07, in addition to subheading
7615.10.9100, HTSUS. Derivative aluminum articles processed in another country from aluminum articles
that were smelted and cast in the United States, provided for in heading 9903.85.09, are not subject to the
additional ad valorem duties.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 7615.10.9100, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e.,
9903.88.15, in addition to subheading 7615.10.9100, 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 respectively.
Please be advised that the aluminum portable fire pit from China may be subject to antidumping duties and
countervailing duties (AD/CVD). Written decisions regarding the scope of AD/CVD orders are issued by the
Enforcement and Compliance office in the International Trade Administration of the Department of
Commerce and are separate from tariff classification and origin rulings issued by Customs and Border
Protection (CBP). You can contact them at https://trade.gov/enforcement/ (click on “Contact Us”). For your
information, you can view a list of current AD/CVD cases at the United States International Trade
Commission website at https://www.usitc.gov/trade_remedy/documents/orders.xls, and you can search
AD/CVD deposit and liquidation messages using CBP’s AD/CVD Search tool at
https://aceservices.cbp.dhs.gov/adcvdweb.
This ruling is being issued under the provisions of Part 177 of the Customs 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, contact
National Import Specialist Dana L. Giammanco at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division