CLA-2-76:OT:RR:NC:N1:164
Scott Breyer
Precision Revolution Mfg.
W2355 U.S. Highway 18
Sullivan, WI 53178
RE: The tariff classification of a gutter shield assembly from Indonesia
Dear Mr. Breyer:
In your letter dated July 21, 2025, you requested a tariff classification ruling on a gutter shield assembly from
Indonesia. Product information was submitted with your request.
The item under consideration is described as a gutter shield assembly to be installed onto rain gutters. The
assembly consists of a frame of extruded grade 6063-T6 aluminum and grade 316L stainless steel
micromesh. After extrusion, the aluminum frame undergoes punching to create slots in its middle portion, is
cut to length, and anodized. Following that, the stainless steel micromesh is tautly placed into the aluminum
frame and secured. During installation, one side of the aluminum frame extends to the back wall and lip of a
rain gutter, and the other side of the frame is fastened to the front lip. Once in place, the combination of the
stainless steel mesh and supporting aluminum frame prevents debris from entering the gutter while allowing
water to flow into it.
Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is in accordance with the
General Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods will be determined
according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the
event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do
not otherwise require, the remaining GRIs 2 through 6 will then be applied in order.
Section XV Note 7, HTSUS, states that the classification of composite articles of base metal containing two
or more base metals are to be treated as articles of the base metal that predominates by weight over each of
the other metals. In this case, the gutter shield assembly is composed of more than one base metal
(aluminum, steel). Based on the information provided, aluminum predominates by weight. Consequently, the
gutter shield assembly is classified as an article of aluminum.
The applicable subheading for the gutter shield assembly will be 7616.99.5190, HTSUS, which provides for
Other articles of aluminum: Other: Other: Other: Other: Other: Other. The general rate of duty will be 2.5
percent ad valorem.
On March 12, 2025, Presidential proclamation 10895 imposed additional tariffs on certain derivative
aluminum products. Additional duties for derivative aluminum products of 50 percent are reflected in
Chapter 99, headings 9903.85.04, 9903.85.07, and 9903.85.08. Products provided by heading 9903.85.08, as
well as products of Chapter 76 provided by 9903.85.04 and 9903.85.07, will be subject to a duty of 50
percent upon the value of the aluminum content. At the time of entry, you must report the Chapter 99 heading
applicable to your product classification, i.e. 9903.85.07, in addition to subheading 7616.99.5190, HTSUS.
Derivative aluminum articles processed in another country from aluminum articles that were smelted and cast
in the United States, provided for in heading 9903.85.09, 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 from all countries
will be subject to an additional 10 percent ad valorem rate of duty. For products covered by subheading
9903.85.07, this additional duty applies to the 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 7616.99.5190, 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