CLA-2-73:OT:RR:NC:N5:117
Lucas Streit
Multivac Inc.
11021 N Pomona Ave.
Kansas City, Missouri 64153
RE: The tariff classification of film transport gripper chain from Germany
Dear Mr. Streit:
In your letter dated June 3, 2025, you requested a tariff classification ruling.
The product under consideration is identified as film transport gripper chain for use in packaging machines.
According to your submission, this steel roller chain consists of springs and gripper clamps that hold the
plastic film in place that will form and seal the packages which are produced on the packaging machine.
In your submission, you suggest that the film transport gripper chain is classifiable in Chapter 84 of the
Harmonized Tariff Schedule of the United States (HTSUS) as a machinery part. We disagree. Section XVI,
Note 1(g) excludes parts of general use, as defined in note 2 to Section XV, of base metal (Section XV).
Based on the description provided, the subject chain is considered a part of general use and would be
excluded from Section XVI.
The applicable subheading for the film transport gripper chain will be 7315.11.0060, HTSUS, which provides
for Chain and parts thereof, of iron or steel: Articulated link chain and parts thereof: Roller chain: Other:
Other. The rate of duty will be free.
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter
99, headings 9903.81.89 and 9903.81.90. Products provided by heading 9903.81.91 will be subject to a duty
of 50 percent upon the value of the steel content. At the time of entry, you must report the Chapter 99
heading applicable to your product classification, i.e. 9903.81.90, in addition to subheading 7315.11.0060,
HTSUS. Derivative iron or steel products processed in another country from steel articles melted and poured
in the United States, provided for in heading 9903.81.92, are not subject to the additional ad valorem duties.
Please note that derivative steel products admitted to a U.S. foreign trade zone under “privileged foreign
status” before March 12, 2025, and entered for consumption on or after March 12, 2025, may be subject to
additional duties under heading 9903.81.93, 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,
including Germany, 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., 9903.01.33, in addition to subheading 7315.11.0060, 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/current.
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 Denise Hopkins at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division