CLA-2-94:OT:RR:NC:N5:433
Kay Wahl OFS 1204 E 6th Street Huntingburg, IN 47542 RE: The tariff classification of metal furniture components from Canada Dear Kay Wahl: In your letter dated September 12, 2025, you requested a tariff classification ruling. In lieu of samples, technical and illustrative literature, product descriptions, and manufacturing processes were provided. Item 1, the “Upper Leg,” item 2, the “Lower Leg,” item 3, the “Lateral Beam,” and item 4, the “Power Raceway,” are 6063-T5 extruded aluminum metal support rails of various lengths that are custom engineered for use in the assembly of modular cubicle workstations. After assembly, the support rail component parts will provide the vertical, horizontal, and diagonal structural skeletal framework of modular cubicle workstations. Further, the support rail components will provide multiple mounting points for additional attachments and accessories (not included) such as brackets, worksurfaces, desks, screens, shelves, fabric panels, privacy panels, modesty panels, power components, and covers. Item 1 rail dimensions will be made available in 46.78”, 25.78”, 4.78” lengths, 1.87” in width, and 1.875” thick. Item 2 rail dimensions will be made available in 55.78”, 34.78”, 13.78” lengths, 7.25” in width, and 1.875” thick. Item 3 rail dimensions will be made available in 74.937” to 78.625” lengths, 3.25” in width, and 1.75” thick. Item 4 rail dimensions will be made available in 53.87”, 65.87”, 77.87” lengths, 1.37” in width, and 1.375” thick. The ruling request seeks classification of the subject merchandise in subheading 9403.90.9045, Harmonized Tariff Schedule of the United States, (HTSUS). We agree. The applicable subheading for the subject merchandise will be 9403.90.9045, HTSUS, which provides for “Other furniture and parts thereof: Parts: Other: Other: Other: Other: Of metal: Other.” The general rate of duty will be free.
Trade Remedy: 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 9403.90.9045, 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. Products of Canada as provided by heading 9903.01.10 in Section XXII, Chapter 99, Subchapter III, U.S. Note 2(j), HTSUS, other than products classifiable under headings 9903.01.11, 9903.01.12, 9903.01.13, 9903.01.14, and 9903.01.15, HTSUS, will be subject to an additional 35 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.10, in addition to subheading 9403.90.9045, HTSUS, listed above. Articles that are entered free of duty under the terms of general note 11 to the HTSUS (U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set forth in subchapter XXIII of Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be subject to the additional ad valorem duties provided for in heading 9903.01.10. If your product is entered duty free as originating under the USMCA, you must report heading 9903.01.14, HTSUS, in addition to subheading 9403.90.9045, HTSUS. 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 Canada are not subject to reciprocal tariffs. For products covered by heading 9903.85.08 this additional duty applies to the non-aluminum content of the merchandise. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.26, in addition to subheading 9403.90.9045, 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) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division