CLA-2-87:OT:RR:NC:N2:201
Luis Rivera
Utility Transportation Carts
2371 Golfview Drive
Orange Park, FL 32003
RE: The tariff classification of an aluminum industrial hand cart from China
Dear Mr. Rivera:
In your letter dated June 10, 2025, you requested a tariff classification ruling.
The item under consideration has been identified as the Haulmax-360, a non-motorized industrial hand cart,
designed to transport goods and supplies at large venues and events. You state that the primary structure is
made of aluminum tubing and panels. The cart is designed with an open platform with swivel casters and
integrated handles. The cart, according to the information you provided, states the dimensions are a
pproximately 60" L x 30" W x 29" H.
The applicable subheading for the Haulmax-360 hand cart will be 8716.80.5010, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for “Trailers and semi-trailers; other vehicles, not
mechanically propelled; and parts thereof: Other vehicles: Farm wagons and carts: Other: Industrial hand
trucks”. The general rate of duty will be 3.2% ad valorem.
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 8716.80.5010, 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. 9903.85.08 in addition to subheading
8716.80.5010, 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. For products covered by heading
9903.85.08 this additional duty applies to the non-aluminum content of the merchandise. 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 8716.80.5010, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8716.80.5010, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03,
in addition to subheading 8716.80.5010, 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, including
information on exclusions and their effective dates, 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/programs-administration/trade-remedies, respectively.
This product may subject to antidumping duties or countervailing duties (AD/CVD). When there is a
question as to whether merchandise is subject to an antidumping or countervailing duty order or considered
to be defined by the scope of an order, such a determination is governed by the U.S. Department of
Commerce’s International Trade Administration (“Commerce”). Commerce issues scope rulings to determine
whether merchandise which is in commercial production is covered by the scope of an antidumping or
countervailing duty order. Commerce’s scope rulings are separate and distinct from decisions issued by CBP
regarding tariff classification and country of origin for purposes such as duty assessment and marking.
To seek a scope ruling, please visit the website of Commerce’s International Trade Administration. A guide
to seeking a scope ruling can be found at
https://access.trade.gov/help/Scope_Ruling_Guidance_(4.1.2022).pdf. A list of current AD/CVD
investigations at the United States International Trade Commission can be viewed on its website at
http://www.usitc.gov. Additionally, messages sent by Commerce to CBP regarding AD/CVD cash deposits
and liquidation can be searched using ACE or CBP’s search tool at
https://trade.cbp.dhs.gov/ace/adcvd/adcvd-public/#.
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 Matthew Sullivan at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division