CLA-2-73:OT:RR:NC:N5:121
9903.01.25
Will Planert
Morris, Manning & Martin LLP
1333 New Hampshire Avenue NW, Suite 800
Washington, DC 20036
RE: The tariff classification of collated steel nails from Oman
Dear Mr. Planert:
In your letter dated July 14, 2025, you requested a tariff classification ruling on behalf of Oman Fasteners,
LLC.
The first item under consideration is described as Paper Collated Galvanized Nails. These nails are made of
one-piece construction from galvanized (zinc coated) carbon steel wire, coated using zinc spray and vinyl,
and collated using paper tape. These paper collated galvanized nails are used in nail guns for various
carpentry and construction applications.
The second item under consideration is described as Plastic Collated Bright Nails. These nails are made of
one-piece construction from drawn carbon steel wire, coated using vinyl, and collated using plastic materials
and coloring material. These plastic collated bright nails are used in nail guns for various carpentry and
construction applications.
The third item under consideration is described as Wire Coil Bright Nails. These nails are made of one-piece
construction from drawn carbon steel wire, coated using vinyl, and collated using copper coated steel wire.
These wire coil bright nails are used in nail guns for various carpentry and construction applications.
The fourth item under consideration is described as Brad Nails. These nails are made of one piece
construction from galvanized (zinc coated) drawn wire, and collated using glue. These brad nails are used in
nail guns for various carpentry and construction applications.
The applicable subheading for the Paper Collated Galvanized Nails will be 7317.00.5508, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for Nails, tacks, drawing pins, corrugated nails,
staples… and similar articles, of iron or steel, whether or not with heads of other materials, but excluding
such articles with heads of copper: Other: Of one piece construction: Made of round wire… Collated nails:
Other: Assembled in a paper strip. The rate of duty will be free.
The applicable subheading for the Plastic Collated Bright Nails will be 7317.00.5507, HTSUS, which
provides for Nails, tacks, drawing pins, corrugated nails, staples… and similar articles, of iron or steel,
whether or not with heads of other materials, but excluding such articles with heads of copper: Other: Of one
piece construction: Made of round wire… Collated nails: Other: Assembled in a plastic strip: Other. The rate
of duty will be free.
The applicable subheading for the Wire Coil Bright Nails will be 7317.00.5503, HTSUS, which provides for
Nails, tacks, drawing pins, corrugated nails, staples… and similar articles, of iron or steel, whether or not
with heads of other materials, but excluding such articles with heads of copper: Other: Of one piece
construction: Made of round wire… Collated nails: Other: Assembled in a wire coil: Other. The rate of duty
will be free.
The applicable subheading for the Brad Nails will be 7317.00.5518, HTSUS, which provides for Nails, tacks,
drawing pins, corrugated nails, staples… and similar articles, of iron or steel, whether or not with heads of
other materials, but excluding such articles with heads of copper: Other: Of one piece construction: Made of
round wire… Collated nails: Other: Other. The rate of duty will be free.
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. 9903.81.89, in addition to subheadings 7317.00.5507 or 7317.00.5503; OR
9903.81.90, in addition to subheadings 7317.00.5508, or 7317.00.5518, 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.
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 of Oman will be
subject to an additional 10 percent ad valorem rate of duty. For products covered by headings 9903.81.89
and 9903.81.90, this additional duty applies to the non-steel 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 subheadings 7317.00.5508, 7317.00.5507, 7317.00.5503, or 7317.00.5518, HTSUS, listed above.
The merchandise in question may be subject to antidumping duties and countervailing duties (AD/CVD).
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 and are separate from tariff
classification and origin rulings issued by Customs and Border Protection (CBP). You can contact them at
https://trade.gov/enforcement/ (click on “Contact Us”). For your information, you can view a list of current
AD/CVD cases at the United States International Trade Commission website at
https://www.usitc.gov/trade_remedy/documents/orders.xls, and you can search AD/CVD deposit and
liquidation messages using CBP’s AD/CVD Search tool at https://aceservices.cbp.dhs.gov/adcvdweb.
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 at https://hts.usitc.gov/.
Regarding your question on the breakdown of the values to use for the steel vs non-steel content, at this time
the NCSD is precluded from issuing a ruling letter concerning the applicability of Section 232 additional
duties. Please see Proclamation 10896 Adjusting Imports of Steel Into the United States dated February 10,
2025.
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 Jennifer Jameson at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division