CLA-2-44:OT:RR:NC:N5:130
TARIFF NO: 4418.11.0000; 4418.19.0000; 9903.01.24; 9903.01.25; 9903.88.03
Mr. Weikang Geng
Weikang Geng
4063 Mora Ln.
Pebble Beach, CA 93953
RE: The tariff classification of wood-frame windows from China
Dear Mr. Geng:
In your letter, dated June 27, 2025, you requested a binding tariff classification ruling on aluminum-clad,
wood-frame windows. Product information and photos were submitted for our review.
The product under consideration is wood-framed windows. From the photos provided, the windows appear
to be fixed-frame. The entire framework of the windows is constructed of engineered wood. The exterior
surface of the windows is overlaid with extruded aluminum cladding for weather protection. The full
construction and interior surface of the windows is exposed wood. The glass panes are installed in the
windows. You do not identify the species of wood from which the windows are made. You indicate that the
windows are for a home renovation and not for commercial sale.
The applicable subheading for the aluminum-clad, wood-frame windows, if made of tropical wood, will be
4418.11.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Builders'
joinery and carpentry of wood, including cellular wood panels and assembled flooring panels; shingles and
shakes: Windows, French-windows and their frames: Of tropical wood. The rate of duty will be 3.2 percent
ad valorem.
The applicable subheading for the aluminum-clad, wood-frame windows, if made from any wood besides
tropical wood, will be 4418.19.0000, HTSUS, which provides for Builders' joinery and carpentry of wood,
including cellular wood panels and assembled flooring panels; shingles and shakes: Windows,
French-windows and their frames: Other. The rate of duty will be 3.2 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, 9903.01.24, in addition to
subheadings 4418.11.0000 or 4418.19.0000, HTSUS, listed above.
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. Products from China will be subject to an
additional 10 percent ad valorem rate of duty. At the time of entry, you must report the Chapter 99 heading
applicable to your product classification, 9903.01.25, in addition to subheadings 4418.11.0000 or
4418.19.0000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 4418.11.0000 or 4418.19.0000, 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, 9903.88.03, in addition to subheadings 4418.11.0000 or 4418.19.0000, 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, 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/remedies/301-certain-products-china, respectively.
Your imported goods may be subject to additional antidumping and countervailing duties for aluminum
extrusions from China. Written decisions regarding the scope of AD/CVD orders are issued by the
Enforcement and Compliance office in the International Trade Administration of the Department of
Commerce (ITA) and are separate from tariff classification and origin rulings issued by Customs and Border
Protection (CBP). General information regarding the ITA and AD/CVD can be found at
https://www.trade.gov/us-antidumping-and-countervailing-duties. The ITA’s “Guide on How to File for an
Antidumping/Countervailing Duty Scope Ruling Request” is available at
https://enforcement.trade.gov/scope/Request-Scope-Ruling.pdf
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 on the World Wide Web 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 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 Laurel Duvall at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division