CLA-2-85:OT:RR:NC:N2:208
Olga Wasilewski
Reilly International
1555 N Michael Dr
Wood Dale, IL 60191
RE: The tariff classification of a laptop accessory from China
Dear Ms. Wasilewski:
In your letter dated August 26, 2025, you requested a tariff classification ruling on behalf of your client,
Novaport LLC.
The merchandise under consideration is an adjustable laptop riser, identified as Novaport LLC part number
CXA001. This item is designed to elevate and support a laptop computer, between 10 and 15.6 inches in
size, for ergonomic purposes. The subject riser consists of three primary aluminum alloy components: a base
that rests on a desk or table, a vented platform to aid airflow and cooling of the laptop during extended use,
and an adjustable arm connecting the base and platform.
In your submission, you suggest classification of the subject laptop accessory under subheading
8473.30.9100, Harmonized Tariff Schedule of the United States (HTSUS). However, since this item does
not incorporate a cathode ray tube, it is more specifically provided elsewhere.
The applicable subheading for this laptop riser will be 8473.30.5100, HTSUS, which provides for "Parts and
accessories (other than covers, carrying cases and the like) suitable for use solely or principally with
machines of heading 8470 to 8472: ... Parts and accessories of the machines of heading 8471: Not
incorporating a cathode-ray tube: . . .Other." The general rate of duty will be Free.
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 8473.30.51000, HTSUS, listed above.
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. 9903.85.08, in addition to subheading 8473.30.5100,
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 of China will be
subject to an additional ad valorem rate of duty of 10 percent on the non-aluminum content of the
merchandise. Currently, your product falls within an excepted subheading. At the time of entry, you must
report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.32, in addition to
subheading 8473.30.5100, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8473.30.5100, 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 8473.30.5100, 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 Lisa Cariello at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division