CLA-2-85:OT:RR:NC:N1:103
Maria A. Richardson
ESAB Corporation
909 Rose Ave. 8th Fl.
North Bethesda, MD 20855
RE: The tariff classification of a welding conduit liner from Mexico
Dear Ms. Richardson:
In your letter dated June 13, 2025, you requested a tariff classification ruling.
The merchandise under consideration is referred to as a welding conduit liner, part number 45-3545, that is
used in metal inert gas welding apparatus to guide welding wire from the wire feeder, through the gun cable,
and up to the contact tip. It is described as a length of spirally wound steel music wire with a machined brass
stop at one end. The liner is imported in lengths up to 34 feet and can accommodate welding wire sizes
between 0.9 millimeters to 1.2 millimeters.
The applicable subheading for the welding conduit liner, part number 45-3545, will be 8515.90.2000,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric (including
electrically heated gas), laser or other light or photon beam, ultrasonic, electron beam, magnetic pulse or
plasma arc soldering, brazing or welding machines and apparatus, whether or not capable of cutting; electric
machines and apparatus for hot spraying of metals or cermets; parts thereof: Parts: Other parts.” The general
rate of duty will be 1.6 percent ad valorem.
Products of Mexico as provided by heading 9903.01.01 in Section XXII, Chapter 99, Subchapter III, U.S.
Note 2(a), HTSUS, other than products classifiable under headings 9903.01.02, 9903.01.03, 9903.01.04, and
9903.01.05, HTSUS, will be subject to an additional 25 percent ad valorem rate of duty. At the time of entry,
you must report the applicable Chapter 99 heading, i.e. 9903.01.01, in addition to subheading 8515.90.2000,
HTSUS, listed above. Articles that are entered free of duty under the terms of general note 11 to the HTSUS
(U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set forth in subchapter XXIII of
Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be subject to the additional ad valorem
duties provided for in heading 9903.01.01. If your product is entered duty free as originating under the
USMCA, you must report heading 9903.01.04, HTSUS, in addition to subheading 8515.90.2000, 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
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. 9903.01.27, in addition to subheading 8515.90.2000, 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 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 Huang at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division