CLA-2-83:OT:RR:NC:N5:121

Ali Rafiei
Metal House LLC
8217 128th Ave Ne
Kirkland, WA 98033

RE: The tariff classification of decorative metal finials and ornaments from Georgia

Dear Mr. Rafiei:

In your letter dated August 15, 2025, you requested a tariff classification ruling.

The first item under consideration is described as a Decorative Metal Post Cap Finial, code 103. It is made from cast iron or cast steel and is designed to be mounted on top of square metal posts in stair railings, gates, or fences.

The second item under consideration is described as a Decorative Wrought Iron Spear Point Finial, code 3432701. This fleur-de-lis style spear tip is made of wrought iron and designed to be mounted to the top of fences, gates, or railing pickets.

The third item under consideration is described as Decorative Scroll Leaves, code 3434000 and code 3434300. These are ornamental metal accessories are made of wrought iron or mild steel and designed for enhancing the visual appeal of wrought iron gates, fences, railings, and furniture.

In your request, you propose classification in subheading 7326.19.0010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other articles of iron or steel: Forged or stamped, but not further worked: Other: Forged. We disagree. Heading 7326, HTSUS, is a residual or basket provision which covers a wide range of iron or steel articles that are not more specifically provided for elsewhere in the HTSUS. The Explanatory Notes (ENs) to heading 7326 state that “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.” Noting that the decorate wrought iron elements are more specifically provided for elsewhere in the tariff, classification in heading 7326, HTSUS, is precluded. The applicable subheading for the Decorative Metal Post Cap Finial, code 103, Decorative Wrought Iron Spear Point Finial, code 3432701, and Decorative Scroll Leaves, code 343400 and code 34343000 will be 8306.29.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Bells, gongs and the like, nonelectric, of base metal…Statuettes and other ornaments, and parts thereof: Other. The rate of duty will be free.

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 Georgia will be subject to an additional ad valorem rate of duty of 10 percent. 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 8306.29.0000, 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 Jennifer Jameson at [email protected].
Sincerely,

(for)
Denise Faingar
Acting Director
National Commodity Specialist Division