CLA-2-85:OT:RR:NC:N2:220
Eric Cantineau
Rackmount.IT LLC
559 S I-35 Frontage Rd
Round Rock, TX 78664
RE: The tariff classification of a rack mounted connector panel from the Netherlands
Dear Mr. Cantineau:
In your letter dated June 2, 2025, you requested a tariff classification.
The merchandise under consideration is referred to as the Rackmount Mounting Kit, which is described as a
19” stamped metal frame incorporating 11 front facing RJ-45 Ethernet sockets and one USB-A socket. In
use, a network appliance and its power adapter are attached to the metal frame, patch cords are connected on
the back side of each socket, and the cables are physically routed to the network appliance for the purpose of
facilitating interconnection. We note that the kit is imported with patch cords but is not equipped with the
network appliance and/or the power adapter.
In your letter, you suggest the Rackmount Mounting Kit is classifiable under subheading 8538.90.6000,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for plastic molded parts of
heading 8535 through 8537, HTSUS. We disagree. The subject electrical connector panel is a stamped
metal frame with multiple electrical sockets permanently mounted on the front face. Electrical connections
are made via the 11 RJ-45 sockets that are present, while the metal frame constitutes a base for equipping
those sockets. As such, the classification of the Rackmount Mounting Kit is more appropriate in previous
subheadings under electrical connection apparatus, and not merely as a plastic molded part.
The applicable subheading for the Rackmount Mounting Kit will be 8537.10.9170, HTSUS, which provides
for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 8535
or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other:
Other: Other.” The general rate of duty will be 2.7 percent ad valorem.
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
8537.10.9170, HTSUS, listed above.
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 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 Karl Moosbrugger at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division