CLA-2-84:OT:RR:NC:N1:164
Virginia Smith
Jasco Products Company
10 E. Memorial Rd.
Oklahoma City, OK 73114
RE: The tariff classification of an outdoor electrical outlet cover from Vietnam
Dear Ms. Smith:
In your letter dated October 6, 2025, you requested a tariff classification ruling regarding an outdoor
electrical outlet cover from Vietnam. Product information was submitted with your request.
The item under consideration is described as an outdoor electrical outlet cover used to protect electrical
receptacles from environmental exposure. It consists of a weather-resistant aluminum alloy shell to surround
and house an electrical receptacle, a hinged polycarbonate (PC) lid to open and close over the front of the
receptacle, a cross-linked polyethylene (XPE) foam gasket for weather sealing, a hinge, and screws. You
assert the outlet cover is specifically designed for outdoor installation on the exterior of a building.
Additionally, you state the aluminum alloy shell accounts for approximately 72 percent of the material
composition.
In your request, you suggest that the correct classification for the outdoor electrical outlet cover is
8538.90.6000, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. Heading 8538,
HTSUS, covers “Parts suitable for use solely or principally with the apparatus of heading 8535, 8536, or
8537.” We agree that the electrical receptacle contained within the subject cover is classified within the
referenced headings. However, it is our view that subject electrical outlet cover is not considered a part of the
outlet for classification purposes. The cover is a separate and distinct commercial identity and is not integral
to the function of the outlet. Accordingly, classification within heading 8538, HTSUS, is not applicable.
You also propose classification in subheading 8302.41.6080, HTSUS, which provides for “Base metal
mountings and fittings suitable for buildings made of iron or steel, of aluminum or of zinc.” We disagree.
Electrical outlets do not have the characteristics of and are not similar or akin to the articles enumerated in
the terms of heading 8302, namely furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks,
chests, and caskets. The outdoor electrical outlet cover, therefore, is not suitable for these articles and cannot
be classified in heading 8302, HTSUS.
Classification under the HTSUS is in accordance with the General Rules of Interpretation (GRIs). GRI 1
provides that the classification of goods will be determined according to the terms of the headings of the
tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely
on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2
through 6 will then be applied in order.
The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official
interpretation of the HTSUS. While not legally binding nor dispositive, the ENs provide a commentary on the
scope of each heading of the HTSUS and are generally indicative of the proper interpretation of these
headings. See T.D. 89-80, 54 Fed. Reg. 35127 (August 23, 1989).
Heading 7616, HTSUS, is a residual or basket provision which covers a wide range of aluminum articles that
are not more specifically provided for elsewhere in the HTSUS. The ENs to heading 7616 state that “This
heading covers all articles of aluminum other than those covered by the preceding headings of this Chapter,
or by Note 1 to Section XV, or articles specified or included in Chapter 82 or 83, or more specifically
covered elsewhere in the Nomenclature.” An article of aluminum can be classified in heading 7616 if it is
determined that the item is not more specifically provided for in any other heading of the tariff. Noting the
outdoor electrical outlet cover is not more specifically provided for in headings 8538, 8302, or any other
heading of the tariff, they can be classified in heading 7616, HTSUS.
The applicable subheading for the outdoor electrical outlet cover will be 7616.99.5190, HTSUS, which
provides for “Other articles of aluminum: Other: Other: Other: Other: Other: Other.” The general rate of duty
will be 2.5 percent ad valorem.
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. 9903.85.07, in addition to subheading 7616.99.5190, 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 Vietnam will be
subject to an additional ad valorem rate of duty of 20 percent. For products covered by heading 9903.85.07,
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. 9903.02.69, in addition to
subheading 7616.99.5190, 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
(C.F.R.), 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 C.F.R. 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 Paul Taylor at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division