CLA-2-76:OT:RR:NC:N5:116
Jiwon Kwon
Cusan Customs Service Incorporation
#309, 35, Magokjungang 2-ro, Gangseo-gu, Seoul, Republic of Korea
Seoul, 07806
South Korea
RE: The tariff classification of aluminum composite panels from South Korea
Dear Mr. Kwon:
In your letter dated November 5, 2025, you requested a tariff classification ruling on behalf of your client,
Hongseong Industrial Co., Ltd.
The products under consideration are described as noncombustible aluminum composite panels and identified
as Architecks® FR. These panels/sheets consist of a 3 mm fire-retardant polyethylene core sandwiched
between two aluminum sheets made from type 3003 aluminum alloy. You indicate that the panels are used in
exterior applications. For tariff purposes, the panels are considered a composite good of which the essential
character is imparted by the aluminum sheets.
The applicable subheading for the aluminum panels/sheets will be 7606.12.3096, HTSUS, which provides for
aluminum plates, sheets and strips, of a thickness exceeding 0.2 mm: rectangular (including square): of
aluminum alloys: not clad: with a thickness of 6.3 mm or less: other: other. The rate of duty will be 3 percent
ad valorem.
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 7606.12.3096, 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., 9903.85.02, in addition to the Chapter
72, 73 or 76 subheadings 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 South Korea
will be subject to an additional ad valorem rate of duty of 15 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 7606.12.3096, 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. You should
also be aware 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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division