CLA-2-85:OT:RR:NC:N2:220
Alan Kashdan
Blank Rome LLP
1825 I Street, N.W.
Washington, DC 20006
RE: The tariff classification of suspension strings from France
Dear Mr. Kashdan:
In your letter dated February 13, 2026, you requested a tariff classification ruling on behalf of SICAME
Group.
There are three items at issue with this request, which are all identified as suspension strings for use in high
voltage, low frequency overhead power transmission systems and individually identified by part numbers
530-002-001 (Item 1), 530-002-012 (Item 2), and 530-002-009 (Item 3).
Item 1 is comprised of various shackles, clevises, connector plates, guard rings, yokes, u-connectors,
suspension clamps, and armor rods of either steel alloy, aluminum alloy, galvanized steel, or aluminum
depending on the item. We note that the steel alloy components make up the majority of the suspension
string. The suspension string also includes a composite insulating component of rubber and fiberglass. In use,
Item 1 provides physical support and tension for energized overhead wires that carry electricity across
transmission towers, while at the same time insulates the tower from the electrical current of the conductor
that it supports.
Items 2 and 3 are comprised of various components including shackles, clevises, connector plates, guard
rings, yokes, u-connectors, suspension clamps, counterweights, and arming bolts of either steel alloy,
aluminum alloy, galvanized steel, or cast iron, depending on the item. Minor differences are noted in the
quantity, type, and material composition of the components. We note that the steel alloy components make up
the majority of both suspension strings. We also note that Items 2 and 3 are not imported with insulating
components. In use, Items 2 and 3 provide physical support and tension for energized overhead wires that
carry electricity across transmission towers.
In your request, you suggest that the correction classification for Item 1 to be 8546.20.0030, 8546.10.0000, or
8546.90.0000, Harmonized Tariff Schedule of the United States (HTSUS). As the primary function of the
device is electrical insulation, we agree with 8546.90.0000.
The applicable subheading for Item 1 will be 8546.90.0000, HTSUS, which provides for “Electrical
insulators of any material: Other.” The general rate of duty will be Free.
For Items 2 and 3, you suggest that the correct classification for those items to be 8546.90.0000,
8548.00.0000, or 8538.90.8180. We disagree.
For Items 2 and 3, we find that, without the insulating component, the suspension string does not meet the
terms of heading 8546, HTSUS, as an “Electrical insulator of any material” and is therefore precluded from
classification in that heading. Furthermore, we find that Items 2 and 3 do not perform an electrical connecting
function, as required for classification in headings 8535 or 8538, HTSUS. Also, we are of the opinion that
Items 2 and 3, imported without the insulating component, primarily provide a structural function and would
not be considered as electrical parts according to the terms of heading 8548, HTSUS.
The suspension string components described in Items 2 and 3 contain alloys of other base metals. Section
XV, Note 7 of the HTSUS, states that the classification of articles of base metal containing two or more base
metals are to be treated as articles of the base metal that predominates by weight over each of the other
metals. Based on the information provided, the predominating metal of the suspension strings is galvanized
steel. Articles of steel are provided for within heading 7326, HTSUS.
Heading 7326, HTSUS, is a residual or basket provision, which covers a wide range of iron or steel articles
that are not more specifically provided for elsewhere in the HTSUS. The Explanatory Notes (ENs) to heading
7326, HTSUS state that “This heading covers all iron or steel articles obtained by forging or punching, by
cutting or stamping or by other processes such as folding, assembling, welding, turning, milling or
perforating other than articles included in the preceding headings of this Chapter or covered by Note 1 to
Section XV or included in Chapter 82 or 83 or more specifically covered elsewhere in the Nomenclature.”
An article of iron or steel can be classified in heading 7326, HTSUS if it is determined that the item is not
more specifically provided for in any other heading of the tariff. Suspension strings without an insulating
component are not specifically covered elsewhere in the tariff. Accordingly, it is classifiable in heading 7326,
HTSUS.
The applicable subheading for Items 2 and 3 will be 7326.90.8688, HTSUS, which provides for “Other
articles of iron or steel: Other: Other: Other: Other: Other.” The general rate of duty will be 2.9 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 the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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 Gary Chaffee at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division