CLA-2-73:OT:RR:NC:N1:164
David Neuburger
Magic Novelty
540 Nepperhan Ave.
4th Floor, Suite D10
Yonkers, NY 10701
RE: The tariff classification of rings from China
Dear Mr. Neuburger:
In your letter dated August 18, 2025, you requested a tariff classification ruling.
The items under consideration are described as rings used for fastening and connecting. You state that they
are used in a variety of industries, including hardware, clothing, accessories, and jewelry. Based on the
submitted information, the items are split rings of steel wire. You clarify that the rings will be imported in
diameters of 6 millimeters (mm), 9 mm, and 20 mm. In your request, you suggest the rings could be
classified under heading 8308, Harmonized Tariff Schedule of the United States (HTSUS), which provides
for Clasps, frames with clasps, buckles, buckle clasps, hooks, eyes, eyelets and the like and parts thereof, of
base metal, of a kind used for clothing, footwear, awnings, handbags, travel goods of other made up articles.
We disagree.
The Explanatory Notes (EN) to heading 8308, in pertinent part, provide that the heading includes “(C)
Clasps, fasteners, and frames with clasps, for handbags, purses, brief-cases, executive-cases or other travel
goods, or for books or wrist-watches.” This EN describes articles which are used to securely close or join the
sides, or ends, of a good together (e.g., handbags). In that scenario, the sides of a handbag, which when left
open leave the handbag’s interior and contents exposed, are held securely closed by the interconnecting parts
of a metal clasp mounted at the corresponding points on each side of the handbag.
The subject rings can be distinguished from clasps and fasteners of the kind described by heading 8308,
HTSUS, because they do not serve to hold two parts of an article together, in the manner a handbag clasp
holds the two sides of the handbag together. As such, the subject rings are not described by the terms of
heading 8308, HTSUS.
Heading 7326, HTSUS, provides for other articles of iron or steel. The ENs to heading 7326 state “This
heading covers all iron or steel articles obtained by forging or punching, by cutting or stamping or by other
processes such as folding, assembling, welding, turning, milling or perforating other than articles included in
the preceding headings of this Chapter or covered by Note 1 to Section XV or included in Chapter 82 or 83 or
more specifically covered elsewhere in the Nomenclature.” Since the subject rings are not more specifically
provided for in heading 8308, or any other heading of the tariff, the rings will be classified in heading 7326,
HTSUS.
The applicable subheading for the rings will be 7326.20.0090, HTSUS, which provides for Other articles of
iron or steel: Articles of iron or steel wire: Other. The general rate of duty will be 3.9 percent ad valorem.
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 subheading 7326.20.0090, HTSUS, listed above.
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 7326.20.0090, 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 China will be
subject to an additional ad valorem rate of duty of 10 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. 9903.01.25, in addition to subheading
7326.20.0090, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 7326.20.0090, 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 subheading 7326.20.0090, 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/.
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)
Denise Faingar
Acting Director
National Commodity Specialist Division