CLA-2-39:OT:RR:NC:N4:415
Adrianne Barkley
Terra Worldwide Logistics Atlanta
1400 Hembree Road
Roswell, GA 30076
RE: The tariff classification of acrylic optical inspection boards from China.
Dear Ms. Barkley:
In your letter dated December 3, 2025, you requested a tariff classification ruling on behalf of your client,
Fuyao North America, Inc.
Images were provided in lieu of a sample.
The product under consideration is described as optical inspection boards. They consist of flat acrylic plastic
boards that have been printed with high contrast geometric line patterns. These boards are specifically
designed and used for optical distortion inspection in the automotive glass manufacturing process. During
the inspection, the board is positioned behind the windshield or other automotive glazing, and the inspection
technician visually observes the printed pattern through the glass. If the straight lines appear wavy or
displaced, it indicates optical distortion or defects in the automotive glass.
In your letter, you suggest the applicable subheading for these optical inspection boards to be under
subheading 9031.49, Harmonized Tariff Schedule of the United States (HTSUS), which provides for
“[m]easuring or checking instruments, appliances and machines, not specified or included elsewhere in this
chapter; profile projectors; parts and accessories thereof: [o]ther optical instruments and appliances: [o]ther.”
We disagree. The optical inspection boards are simply printed acrylic plates with a metal hinge, magnets,
and a plastic holder. It does not contain any optical technology (such as a laser or camera) to optically
determine if there are flaws in the windshield. Instead, the acrylic panel is viewed through the windshield
looking for any distortion by evaluating if the printed lines are wavy or straight. Accordingly, heading 9031,
HTSUS, is not appropriate for this product. Rather, it will be classified under heading 3926 as the acrylic
board would impart the essential character to this product, General Note of Interpretation 3(b) noted.
As these optical inspection boards would be considered articles of plastic, and as they are not more
specifically provided for elsewhere, the applicable subheading will be 3926.90.9989, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for “[o]ther articles of plastics and articles of other
materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther.” The column one, general rate of duty is 5.3
percent ad valorem.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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 CBP Regulations (19 CFR 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 Kristopher Burton at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division