CLA-2-73:OT:RR:NC:N5:116
Aiswarya S. Baiju
RVL Metals Inc.
1448 Yorkshire Drive
Streamwood, Illinois 60107
RE: The tariff classification of stainless steel tubes from India
Dear Mr. Baiju:
In your letter dated September 23, 2025, you requested a tariff classification ruling.
The products to be imported are Type 304 stainless steel square and rectangular tubes. According to your
submission, these welded, cold-drawn, polished tubes have a wall thickness of 0.180 inch (4.57 mm) and will
be used in structural and architectural applications (e.g., handrails, supports, etc.). The tubes, some of which
are drilled and others that are not drilled, will be imported in 24-foot lengths. Based on the submitted
pictures, the drilled tubes appear to have one large circular hole on one end with two smaller holes on each
end and four smaller holes.
The applicable subheading for the drilled and undrilled stainless steel tubes will be 7306.61.3000,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for other tubes, pipes and hollow
profiles (for example, open seamed or welded, riveted or similarly closed), of iron or steel: other, welded, of
noncircular cross section: of square or rectangular cross section: having a wall thickness of 4 mm or more: of
alloy steel. The rate of duty will be free.
On March 12, 2025, Presidential proclamations 10895 and 10896 imposed additional tariffs on products of
steel and aluminum. Additional duties for steel and aluminum products of 50 percent are reflected in Chapter
99, heading 9903.81.87 for steel and heading 9903.85.02 for aluminum. Products classified under subheading
7306.61.3000, HTSUS, may be subject to additional duties. At the time of entry, you must report the Chapter
99 heading applicable to your product classification, i.e. 9903.81.87, in addition to the Chapter 72, 73 or 76
subheadings listed above.
Effective August 27, 2025, Executive Order 14339 imposed additional duties on products from India. At this
time, products of India provided by heading 9903.01.84, except for products described in headings
9903.01.85 – 9903.01.89, will be subject to an additional ad valorem rate of duty of 25 percent. 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.,9903.01.87, in addition to subheading 7306.61.3000, HTSUS, listed above.
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 India will be
subject to an additional ad valorem rate of duty of 25 percent. 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., 9903.01.33, in addition to subheading 7306.61.3000, 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/current.
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 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, contact
National Import Specialist Angelia Amerson at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division