CLA-2-39:OT:RR:NC:N5:137
Jin Kim
ACI Law Group, PC
6 Centerpointe Dr., Ste. 630
La Palma, CA 90623
RE: The tariff classification of a glass fiber reinforced hollow plastic profile from China
Dear Mr. Kim:
In your letter dated December 17, 2025, you requested a tariff classification ruling on behalf of your client,
U.S. Futaba, Inc.
The product under consideration is referred to as “Glass Fiber Reinforced Plastic (GFRP) Closet Rod”. The
product is composed of a polyester resin that has been reinforced with glass fibers. The rod is hollow with a
consistent cross-section and is available in both round and oval profiles, each cut to a standard length for ease
of installation. The rods are painted in various decorative finishes such as dull brass, dull chrome, dull nickel,
matte black, and oil-rubbed bronze. The product is imported in a ready-to-use condition as a horizontal rod
installed in a closet to hold clothing suspended from hangers.
In your submission, you assert that the correct classification for the subject closet rods is within subheading
3926.30.5000, Harmonized Tariff Schedule of the United States (HTSUS), as a fitting for furniture. We
disagree. The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitutes
the official interpretation of the Harmonized System at the international level. While neither legally binding
nor dispositive, the ENs provide a commentary on the scope of each heading of the HTSUS and are generally
indicative of the proper interpretation of these headings. See T.D. 89-80, 54 Fed. Reg. 35127 (August 23,
1989). The ENs for heading 3916 indicate these rods, which have only been cut to length and painted, would
still be correctly classified under this heading. As this product would be specified or included elsewhere, it
would be excluded from classification under heading 3926, to include 3926.30.5000, HTSUS, as proposed.
The applicable subheading for the glass fiber reinforced plastic closet rod will be 3916.90.5000, HTSUS,
which provides for monofilament of which any cross-sectional dimension exceeds 1 mm, rods, sticks and
profile shapes, whether or not surface-worked but not otherwise worked, of plastics: of other plastics: other:
other: other. The general rate of duty will be 5.8 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 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 Christina Allen at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division