CLA-2-38:OT:RR:NC:N3:139
David Driesbach
Madera Advanced Construction Materials, Incorporated.
14420 Spyglass Circle
Chowchilla, CA 93610
RE: The tariff classification of external wall coverings from Turkey
Dear Mr. Driesbach:
In your letter filed on behalf of Guven Madencilik San Tic A.S. dated July 6, 2025, and an subsequent email
communication you requested a tariff classification ruling.
There are two items under review, with the product code designations of ExperTherm TR 10, and
ExperTherm DR 13. ExperTherm TR 10 is described as an exterior stucco for residential and commercial
buildings, and is said to consist of cement, a polymer and pumice. ExperTherm DR 13 is described as an
overlay that will be applied to the surface of ExperTherm TR 10 to provide an attractive finish coat, and also
to harden the surface of the ExperTherm TR 10 product. It is said to consist of a white cement, a polymer and
a mineral.
The applicable subheading for ExperTherm TR 10, and ExperTherm DR 13 will be 3824.99.9397,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for Prepared binders for foundry
molds or cores; chemical products and preparations of the chemical or allied industries (including those
consisting of mixtures of natural products), not elsewhere specified or included: Other: Other: Other: Other:
Other: Other: Other. The general rate of duty will be 5 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. 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. 9903.01.32, in addition to subheading 3824.99.9397, 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 John Bobel at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division