CLA-2-83:OT:RR:NC:N4:422
Mr. Carlos Llanos
Crestview Partners LLC dba McIntire Business Products
128 Hall Street Suite K
Concord, NH 03301
RE: The tariff classification of a wire spool and wire binding spines from China
Dear Mr. Llanos:
In your letter dated September 27, 2025, you requested a tariff classification ruling. Product photos and
website information were submitted for review.
The merchandise under consideration is referred to as a “3:1 Pitch 1/4" White Wire-O Spool (90,000
Loops),” Item#91WM14SPLWHT, and “Black 3:1 Wire-O Twin-Loop Binding Spines (Box of 100),”
Item#WIREOBINDINGBK31-GRP.
The first item, the “3:1 Pitch 1/4" White Wire-O Spool (90,000 Loops),” Item#91WM14SPLWHT, is a
finished steel product with polyethylene terephthalate (PET) coating. It is wound on a spool and is used on
automatic wiring machines. The wire spool is used for wire binding to bind reports, calendars, notebooks,
and presentations. It features 90,000 loops of wire binding. The wire diameter (thickness) varies in size: 1/4",
5/16", 3/8", 7/16", 1/2", 9/16", 5/8", 3/4", 7/8", 1", 1 1/8", and 1 1/4."
The second item, the “Black 3:1 Wire-O Twin-Loop Binding Spines (Box of 100),”
Item#WIREOBINDINGBK31-GRP, s a finished steel product with PET coating. It is cut into 11-inch pieces
to wire bind loose-leaf reports, presentations, calendars, notebooks, and journals. The wire diameter
(thickness) varies in size: 3/16", 1/4", 5/16", 3/8", 7/16", 1/2", and 9/16."
In your request, you propose classification of the merchandise in subheading 8305.10.00, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for fittings for looseleaf binders or files. We
disagree. The wire spool and wire binding spines are not of the same class or kind provided in subheading
8305.10.00, HTSUS. They are more appropriately classified under another subheading.
The applicable subheading for the “3:1 Pitch 1/4" White Wire-O Spool (90,000 Loops),”
Item#91WM14SPLWHT, and the “Black 3:1 Wire-O Twin-Loop Binding Spines (Box of 100),”
Item#WIREOBINDINGBK31-GRP will be 8305.90.6000, HTSUS, which provides for “Fittings for
looseleaf binders or files, letter clips, letter corners, paper clips, indexing tags and similar office articles, and
parts thereof, of base metal; staples in strips (for example, for offices, upholstery, packaging), of base metal:
Other, including parts: Other.” The general rate of duty will be 5.7 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 8305.90.6000, 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 from all countries
will be subject to an additional 10 percent ad valorem rate of duty. 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
8305.90.6000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 9608.40.8000, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15,
in addition to subheading 8305.90.6000, 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
(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 Dana L. Giammanco at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division