CLA-2-72:OT:RR:NC:N5:117
David Eisenberg
Micro-Tracers, Inc.
195 Vasquez Avenue
San Francisco, California 94127
RE: The tariff classification of steel grit from China
Dear Mr. Eisenberg:
In your letter dated June 23, 2025, you requested a tariff classification ruling.
The products under consideration are nonalloy (carbon) steel and stainless steel grit used to manufacture
Microtracers® that are designed to assure the quality of mixed formula animal, poultry, and fish feed. In an
email to this office, you provided sieve analyses of the two products you purchase and indicated that both
types of grit have particle sizes between 0.1 mm and 0.4 mm.
Powders, which include steel powders, are defined in Section XV, Note 8(b) of the Harmonized Tariff
Schedule of the United States (HTSUS) as “Products of which 90 percent or more by weight passes through a
sieve having a mesh aperture of 1 mm.” Steel granules are defined in Chapter 72, Note 1(h) as “Products of
which less than 90 percent by weight passes through a sieve with a mesh aperture of 1 mm and of which 90
percent or more by weight passes through a sieve with a mesh aperture of 5 mm.”
The applicable subheading for the nonalloy steel grit and stainless steel grit meeting the tariff definition for
granules will be 7205.10.0000, HTSUS, which provides for Granules and powders, of pig iron, spiegeleisen,
iron or steel: Granules. The rate of duty will be free.
The applicable subheading for the stainless steel grit meeting the tariff definition for powder will be
7205.21.0000, HTSUS, which provides for Granules and powders, of pig iron, spiegeleisen, iron or steel:
Powders: Of alloy steel. The rate of duty will be free.
The applicable subheading for the nonalloy steel grit meeting the tariff definition for powder will be
7205.29.0000, HTSUS, which provides for Granules and powders, of pig iron, spiegeleisen, iron or steel:
Powders: Other. The rate of duty will be free.
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, i.e., 9903.01.24, in addition
to subheadings 7205.10.0000, 7205.21.0000, and 7205.29.0000, 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. At this time products from all countries,
including 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, i.e., 9903.01.25, in addition to
subheadings 7205.10.0000, 7205.21.0000, and 7205.29.0000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 7205.10.0000, 7205.21.0000, and 7205.29.0000, 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, i.e., 9903.88.03, in addition to subheadings 7205.10.0000, 7205.21.0000, and
7205.29.0000, 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, including
information on exclusions and their effective dates, 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/programs-administration/trade-remedies, respectively.
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/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 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, contact
National Import Specialist Denise Hopkins at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division