CLA-2-76:OT:RR:NC:N1:164
Brenda Lang
American Lamprecht
3500 Boston St., Suite 420
Baltimore, MD 21224
RE: The tariff classification of collapsible aluminum tubes from France
Dear Ms. Lang:
In your letter dated June 30, 2025, you requested a tariff classification ruling regarding collapsible aluminum
tubes from France on behalf of your client, Alltub France SAS. Product information was submitted with your
request.
The items under consideration are described as empty collapsible aluminum tubes which will be used as
packaging for different materials in the cosmetics, pharmaceuticals, food, household, and industrial sectors.
The subject tubes are predominantly grade A7 aluminum cylinders with polymeric coatings and
polypropylene plastic caps. One end of the tube is cylindrical and open, and the opposing end is formed into
an open nozzle with M11 threading. During the final stages of production, the nozzles are sealed with a
membrane and capped with a threaded polypropylene plastic cap. At importation, the tubes will be 28
millimeters in diameter, 145 millimeters in length, and average 5.35 grams in weight. Finally, the product
brochure states that the maximum fill volume for the 28-millimeter diameter tube is 80 milliliters.
The applicable subheading for the collapsible aluminum tubes will be 7612.10.0000, 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
liquefied gas), of a capacity not exceeding 300 liters, whether or not lined or heat insulated, but not fitted
with mechanical or thermal equipment: Collapsible tubular containers. The general rate of duty will be 2.4
percent ad valorem.
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. 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
7612.10.0000, 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)
James Forkan
Acting Director
National Commodity Specialist Division