CLA-2-80:OT:RR:NC:N1:164
Jamie Thomas
Harimatec
1965 Evergreen Blvd., St. 400
Duluth, GA 30096
RE: The tariff classification of tin-lead solder powder from France
Dear Jamie Thomas:
In your letter dated January 12, 2026, you requested a tariff classification ruling. Technical information was
submitted with your request.
The item under consideration is tin-lead solder powder (“Sn63Pb37”) which will be mixed with other
ingredients to make solder paste after importation. Based on the submitted documentation, the powder is
approximately 63 percent tin and approximately 37 percent lead. As indicated on the submitted certificate of
analysis, 100 percent of the powder by weight is less than or equal to 50 micrometers in particle size. At
importation, the solder powder will be packaged in a heat-sealing aluminum foil bag and labeled. You
propose that the powder is classified in subheading 8001.20.0090, Harmonized Tariff Schedule of the United
States (HTSUS), which provides for “Unwrought tin: Tin alloys: Containing, by weight, more than 25
percent of lead.” We disagree.
Classification under the HTSUS is in accordance with the General Rules of Interpretation (GRIs). GRI 1
provides that the classification of goods will be determined according to the terms of the headings of the
tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely
on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2
through 6 will then be applied in order.
The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official
interpretation of the HTSUS. While not 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 to heading 8001 state “This heading covers unwrought tin in blocks, ingots, pigs, slabs, bars, sticks
or similar forms, and fragments, granules and similar products, of tin…” In addition, the ENs to heading
8001 specify that “This heading excludes tin powders and flakes (heading 8007).” As a result, the powder at
issue is not classified as unwrought tin.
Section XV Note 8(b) defines powders as “Products of which 90% or more by weight passes through a sieve
having a mesh aperture of 1 mm.” As described, 100 percent of the product by weight is less than or equal to
50 micrometers in particle size. Consequently, the subject powder meets the definition of powder outlined in
Section XV. According to EN (A)(4) to Section XV, “The classification of mixtures of metal powders which
have not been sintered, is however, governed by Note 7 to this Section.” Section XV Note 7 states that
“…articles of base metal…containing two or more base metals are to be treated as articles of the base metal
predominating by weight over each of the other materials.” As you specified, the solder powder is 63 percent
tin by weight.
The applicable subheading for the tin-lead solder powder will be 8007.00.3200, HTSUS, which provides for
“Other articles of tin: Powders and flakes.” The general rate of duty will be 2.8 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
(C.F.R.), 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 C.F.R. 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 Paul Taylor at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division