CLA-2-94:OT:RR:NC:N5:433
Carolyn Leski
BCB International Inc.
1010 Niagara Street
Buffalo, NY 14213
RE: The tariff classification of metal furniture from Canada
Dear Ms. Leski:
In your letter dated October 23, 2025, you requested a tariff classification ruling on behalf of LC Bakery
Equipment Services (LCB). In lieu of samples, technical and illustrative literature and product descriptions
are provided for review.
The “5000 Series Bakery Oven Racks” are a group of floor standing, assembled, and equipped baking storage
racks affixed to thermoplastic wheel casters. The racks will be constructed of stainless steel metal or
aluminum metal and will be made available in two variations, each with different dimensions. The stainless
steel racks and the aluminum racks will be used during the preparation, baking, storage, and display of
bakers’ goods. The stainless steel metal single rack and the aluminum metal single rack dimensions will
approximate 20” in length, 26” in depth, and 70” in height. The stainless steel metal double rack and the
aluminum metal double rack dimensions will approximate 29” in length, 36” in depth, and 70” in height. The
single and double stainless steel metal racks and the single and double aluminum metal racks will be
equipped with interchangeable wire mesh decking and pan holders (non-wire mesh decking).
The ruling request seeks classification of the stainless steel and aluminum bakery oven racks in subheading
8419.90.9580 Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machinery,
plant or laboratory equipment, whether or not electrically heated (excluding furnaces, ovens and other
equipment of heading 8514), for the treatment of materials by a process involving a change of temperature
such as heating, cooking, roasting, distilling, rectifying, sterilizing, pasteurizing, steaming, drying,
evaporating, vaporizing, condensing or cooling, other than machinery or plant of a kind used for domestic
purposes; instantaneous or storage water heaters, nonelectric; parts thereof: Parts: Other: Other: Other.”
Alternatively, the ruling request suggests 8417.90.0000, HTSUS, which provides for “Industrial or laboratory
furnaces and ovens, including incinerators, nonelectric, and parts thereof: Parts.” We disagree.
The subject racks are not integral to the function of an industrial oven or machine. Rather, they are separate
and distinct products allowing for storage, transport, cooling, or cooking multiple batches of goods. As such,
the bakery oven racks are not classified as parts of a machine of headings 8417 or 8419, HTSUS.
The applicable subheading for the subject merchandise will be 9403.20.0086, HTSUS, which provides for
“Other furniture and parts thereof: Other metal furniture: Other: Counters, lockers, racks, display cases,
shelves, partitions and similar fixtures: Other.” The general rate of duty will be free.
Trade Remedy:
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter
99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as
products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 percent upon
the value of the steel content. At the time of entry, you must report the Chapter 99 heading applicable to your
product classification, i.e. 9903.81.91, in addition to subheading 9403.20.0086, HTSUS. Derivative iron or
steel products processed in another country from steel articles melted and poured in the United States,
provided for in heading 9903.81.92, are not subject to the additional ad valorem duties.
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 9403.20.0086, 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 9403.20.0086, 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 9403.20.0086, 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. 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 9403.20.0086, HTSUS, listed above. For
products covered by heading 9903.81.91(steel derivative) and for products covered by heading 9903.85.08
(aluminum derivative) this additional duty applies to the non-steel and 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. 9903.81.91 and 9903.85.08, in addition to subheading 9403.20.0086, 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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division