CLA-2-73:OT:RR:NC:N5:433
Richard Rice
Samoa Corporation
90 Monticello Rd
Weaverville, NC 28787
RE: The tariff classification of a metal container from Spain
Dear Mr. Rice:
In your letter dated October 10, 2025, you requested a tariff classification ruling. In lieu of samples,
illustrative literature and a description are provided for review.
Item 373300, the “Mobile Waste Oil Gravity Collection Unit” is a 70 liter (18.49 gallon) steel cylindrical oil
drainage container. A collection bowl is affixed to the container. The container will allow for the collection
and discharge of motor vehicle waste oil and other fluids. A hydraulic coupler is located at the container
base; when the container is filled, a discharge pump kit will connect to the hydraulic coupler and allow for
the container’s contents to be emptied. In the condition at the time of U.S. importation, the mobile waste oil
gravity collection unit will not include the discharge pump kit. A carrying handle and four wheeled casters
are mounted to the container base and will allow for the unit to be positioned and repositioned. The container
is not lined, or heat insulated and contains no mechanical or thermal equipment.
The applicable subheading for the subject merchandise will be 7310.10.0090, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for “Tanks, casks, drums, cans, boxes and similar containers, for
any material (other than compressed or liquefied gas), of iron or steel, of a capacity not exceeding 300 liters,
whether or not lined or heat insulated, but not fitted with mechanical or thermal equipment: Of a capacity of
50 liters or more: 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. 9903.81.90, in addition to subheading 7310.10.0090, 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.
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 the European
Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15
percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General
duty rate. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.02.20, in addition to subheading 7310.10.0090, 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