CLA-2-73:OT:RR:NC:N4:422
Ms. Julie E Hartenfels
William B Skinner Inc
300 Route 17 South, Suite 3c
Lodi, NJ 07644
RE: The tariff classification of mouse and rat traps from China
Dear Ms. Hartenfels:
In your letter dated June 24, 2025, on behalf of your client, Pic Corporation, you requested a tariff
classification ruling. A photograph was submitted for review.
The merchandise consists of mouse traps, Items MTW-4 and MTW-2 and a rat trap, Item RTW-1. You have
indicated that the mouse and rat traps assist in killing rodents and are designed for household use.
Mouse traps, Item MTW-4 and Item MTW-2, measure approximately 4.00 inches long by 1.80 inches wide
by 0.75 inches high. Both mouse traps contain a wooden base platform, an iron hammer, an iron catch, an
iron holding bar, and a steel spring.
Rat trap, Item RTW-1, measures approximately 6.90 inches long by 3.30 inches wide by 1.25 inches high.
The rat trap contains a wooden base platform, an iron hammer, an iron catch, an iron holding bar, and a steel
spring.
The items are considered composite goods within the meaning of General Rule of Interpretation (GRI) 3. The
mouse and rat traps contain a wooden base platform, an iron hammer, an iron catch, an iron holding bar, and
a steel spring. The primary functional components of the mouse and rat traps are the iron and steel
components, which, when tripped, release the steel spring and iron hammer and traps the rodents. It is the
opinion of this office that the iron/steel components imparts the essential character of the mouse and rat traps.
In accordance with GRI 3(b), the mousetrap will be classified in heading 7323.
You propose classification of the mouse traps, Item MTW-4 and Item MTW-2, and the rat trap, Item RTW-1,
in subheading 4421.99.9880, Harmonized Tariff Schedule of the United States (HTSUS), which provides for
Other articles of wood. We disagree. The mouse and rat traps are not an article of wood, but a household
article of iron or steel in heading 7323. Therefore, classification in subheading 4421.99.9880 is precluded.
The applicable subheading for the mouse traps, Item MTW-4 and Item MTW-2, and the rat trap, Item
RTW-1, will be 7323.90.9080, HTSUS, which provides for “Table, kitchen or other household articles and
parts thereof, of iron or steel; Other: Other: Other: Other. Other.” The rate of duty will be 3.4 percent 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 7323.90.9080, HTSUS, listed above.
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 7323.90.9080,
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.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 7323.99.9080, 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 7323.99.9080, 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 Dana L. Giammanco at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division