CLA-2-73:OT:RR:NC:N5:433
Dayna Larsen
Noatum Logistics
20 N. Martingale Road, Suite 200
Schaumburg, IL 60173
RE: The tariff classification of a metal container from Canada.
Dear Dayna Larsen:
In your letter dated July 3, 2025, on behalf of Hoover Circular Solutions, you request a tariff classification
ruling. In lieu of samples, technical and illustrative literature, and a product description were provided.
Item CS-87 CF/2465L, the “NA Catalyst Bin,” is a 10-gauge 3/16” carbon steel intermediate bulk container
(IBC) for the storage and transport of goods. The container will be used in the petroleum refining, gas
processing & petrochemical manufacturing industries for the storage and transport of fresh, spent, and
precious metal catalysts. The container can be vertically stacked, has eyebolt lift lugs for crane lifting, and
incorporates 4-way entry channels to accommodate handling by forklifts and other mechanical equipment.
The container has a 16” in diameter lid with wingnuts that will hermetically seal the container’s contents.
The container dimensions approximate 52” in width, 59” in depth, 85” in height, and has a storage capacity
of 2,465 liters.
The applicable subheading for the subject merchandise will be 7309.00.0030, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for “Reservoirs, tanks, vats and similar containers for any
material (other than compressed or liquefied gas), of iron or steel, of a capacity exceeding 300 liters, whether
or not lined or heat insulated, but not fitted with mechanical or thermal equipment: Tanks.” The general rate
of duty will be free.
Trade Remedy:
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, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as
products of Chapter 73 provided by 9903.81.89 and 9903.81.90, 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 7309.00.0030, 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
Products of Canada as provided by heading 9903.01.10 in Section XXII, Chapter 99, Subchapter III, U.S.
Note 2(j), HTSUS, other than products classifiable under headings 9903.01.11, 9903.01.12, 9903.01.13,
9903.01.14, and 9903.01.15, 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. 9903.01.10, in addition to
subheading 7309.00.0030, 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 9903.01.10. If your product is entered
duty free as originating under the USMCA, you must report heading 9903.01.14, HTSUS, in addition to
subheading 7309.00.0030, 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,
including Canada, will be subject to an additional 10 percent ad valorem rate of duty. For products covered
by heading [9903.81.91 or 9903.85.08] this additional duty applies to the [non-steel or 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 7309.00.0030, 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 Dharmendra Lilia at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division