CLA-2-76:OT:RR:NC:N1:164
Myles Holloway
American Lamprecht Transport
3500 Boston St., Suite 420
Baltimore, MD 21224
RE: The tariff classification of empty aluminum cartridges from France
Dear Mr. Holloway:
In your letter dated June 5, 2025, you requested a tariff classification ruling for empty aluminum cartridges
from France on behalf of your client, Alltub France SAS. Product information was submitted with your
request and augmented by subsequent correspondence.
The items under consideration are described as empty aluminum cartridges for use with caulking guns. You
state that the cartridges are used in various industries such as automotive, construction, and public works. The
rigid and tubular cartridges contain and protect substances such as mastic, glue, and sealant during
transportation, storage, and use. On one end, the cartridges feature a protrusion with external threading of
size M15 × 1.50 millimeters (mm). The opposite end of the cartridge may be shaped to a rolled rim, crimping
flange, or straight rim.
The subject cartridges are composed of 1070 aluminum alloy and are 46.8 mm in diameter by 215 mm in
length. Furthermore, the cartridges weigh 31.3 grams and have a capacity of 310 milliliters. At importation,
the aluminum cartridges will be empty and without accessory components.
The applicable subheading for the empty aluminum cartridges will be 7612.90.1090, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for Aluminum casks, drums, cans, boxes and similar
containers (including rigid or collapsible tubular containers), for any material (other than compressed or
liquified gas), of a capacity not exceeding 300 liters, whether or not lined or heat insulated, but not fitted with
mechanical or thermal equipment: Other: Of a capacity not exceeding 20 liters: Other. The general rate of
duty will be 5.7 percent ad valorem.
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
7612.90.1090, 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.
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. 9903.01.33, in addition to subheading 7612.90.1090, 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
(C.F.R.), 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 C.F.R. 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 Paul Taylor at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division