CLA-2-85:OT:RR:NC:N2:212
Jiwon Kwon
Cusan Customs Service Incorporation
#309, 35, Magokjungang 2-ro, Gangseo-gu,
Seoul 07806
South Korea
RE: The tariff classification of grounding bar from Korea
Dear Jiwon Kwon:
In your letter dated November 16, 2025, you requested a tariff classification ruling on behalf of your client,
ILooks Company, Ltd.
The merchandise at issue with this request is identified as the Earth Bar, which is identified by three model
numbers, IL-IB, IL-EB2, and IL-EB3. The subject bar is further described as an uninsulated busbar which
incorporates multiple screw down terminals or poles. Each model ranges in the number of poles and could
range from 3 to 30, depending on the needs of the end user. The subject bars are comprised of tin-plated
copper and are used to connect ground wires within distribution panels, control panels, and other electrical
equipment.
In your request, you suggest that the correct classification for the bars should be 8538.90.8160, Harmonized
Tariff Schedule of the United States (HTSUS). We disagree.
The suggested classification is for those articles that are considered parts of goods classified within headings
8535 through 8537, HTSUS. However, we must first consider Note 2 to Section 16 of the HTSUS, which
states, in part, that parts of machines that are considered goods within Chapters 84 and 85 are to be classified
in their respective headings. The subject bars are used to make electrical connections and facilitate the
grounding of electrical machinery. This function, in our view, is accurately described within the terms of
heading 8536, HTSUS. As such, classification within heading 8538, HTSUS, is not applicable.
The applicable subheading for the Earth Bar, Model Numbers IL-IB, IL-EB2, and IL-EB3, will be
8536.90.8085, HTSUS, which provides for "Electrical apparatus…for making connections to or in electrical
circuits…for a voltage not exceeding 1,000 V: Other apparatus: Other: Other." The general rate of duty will
be 2.7 percent ad valorem.
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. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.56, in addition to subheading
8536.90.8085, 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 Luke LePage at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division