CLA-2-73:OT:RR:NC:N5:433
Will Planert
Morris, Manning & Martin, LLP
1333 New Hampshire Avenue NW, Suite 800
Washington, DC 20036
RE: The tariff classification of metal cans and can ends (lids and bases) from Japan
Dear Mr. Planert:
In your letter dated August 7, 2025, you requested a tariff classification ruling on behalf of Stone Brewing
Co., LLC dba Sapporo-Stone Brewing Co. (SSB). In lieu of samples, illustrative literature, descriptions, and
a manufacturing synopsis are provided for review.
Item 1, the “22-Ounce Steel Cans” are tin plate steel sheet containers used for the commercial conveyance,
packaging, storage, and transport of beer beverages. The cans will be stamped in ink, compounds, and
coatings with beer logos using non-steel materials. The cans are not embossed, lined or heat insulated, and
the cans contain no mechanical or thermal equipment.
Item 2, the “Stay on Tab Lids” are tin plate steel sheet can ends used for the commercial conveyance,
packaging, storage, and transport of beer beverages. In the condition at the time of U.S. importation, item 1
and item 2 will not be welded or crimped together. Item 1 and item 2 will be imported together,
unassembled, and in equal quantities. Item 2 will not be imported separately and in unequal quantities. After
U.S. importation, SSB will assemble the 22-ounce steel can and steel can ends, fill the containers with
beverages, seal, and package the final articles for retail sale.
The ruling request seeks classification of item 1 and item 2 in subheading 7310.21.0075, Harmonized Tariff
Schedule of the United States, (HTSUS), and confirmation of the applicable Chapter 99 provisions.
The applicable subheading for item 1 and item 2 imported together, unassembled, and in equal quantities will
be 7310.21.0075 Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Tanks,
casks, drums, cans, boxes and similar containers, for any material (other than compressed or liquefied gas), of
iron or steel, of a capacity not exceeding 300 liters, whether or not lined or heat insulated, but not fitted with
mechanical or thermal equipment: Of a capacity of less than 50 liters: Cans which are to be closed by
soldering or crimping: Other.” The 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 7310.21.0075, 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 Japan will be
subject to an additional ad valorem rate of duty of 15 percent. For products covered by heading 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. 9903.02.30, in addition to
subheading 7310.21.0075, 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