CLA-2-83:OT:RR:NC:N5:121
Angela Xue
Angela Ying Xue
1805 Borrego Dr.
West Covina, CA 91791
RE: The tariff classification of a Paper Metal Vine Tie from Thailand
Dear Ms. Xue:
In your letter dated August 15, 2025, you requested a tariff classification ruling on behalf of Saveway
Supplies, Inc.
The article under consideration is described as a Paper Metal Vine Tie. It is a flexible twist tie that is
comprised of galvanized steel wire sandwiched between laminated paper. The tie measures approximately 8
inches in length and 0.25 inches in width. This tie is used in gardening, landscaping, and agriculture for
training plants by securing them to support structures.
Classification in heading 4811, Harmonized Tariff Schedule of the United States (HTSUS), is not
appropriate. The product is a composite good made of paper and metal wire, where the wire is the functional
part of the product. As the wire imparts the essential character, classification under the paper provision is
precluded.
The applicable subheading for the Paper Metal Vine Tie will be 8309.90.0080, HTSUS, which provides for
Stoppers, caps and lids (including crown corks, screw caps and pouring stoppers), capsules for bottles,
threaded bungs, bung covers, seals and other packing accessories, and parts thereof, of base metal: Other:
Other: Of steel. The rate of duty will be 2.6 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 of Thailand will be
subject to an additional ad valorem rate of duty of 19 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.61, in addition to subheading
8309.90.0080, 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/.
Additionally, you requested that the Paper Metal Vine Tie be considered for duty-free treatment under
subheading 9817.00.50, HTSUS. Section 177.7 of the Customs Regulations (19 C.F.R. §177.7) provides that
rulings will not be issued in certain circumstances. Specifically, Part 177.7(b) reads, in pertinent part: No
ruling letter will be issued with respect to any issue which is pending before the United States Court of
International Trade, the United States Court of Appeals for the Federal Circuit or any court of appeal
therefrom. As such, CBP will not issue a ruling regarding the eligibility of the Paper Metal Vine Tie under
subheading 9817.00.50, HTSUS, at this time. The classification determination may be impacted by court
cases currently pending in the Court of International Trade. See Great States Corporation DBA American
Lawn Mower Co. v. United States, Court No. 24-00216; Melnor Inc. v. United States, Court No. 25-00052;
and Hydro Gear v. United States, Court No. 23-00044.
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)
Denise Faingar
Acting Director
National Commodity Specialist Division