CLA-2-84:OT:RR:NC:N1:164
Michael Wyche
Rotaloc International, LLC
9903 Titan Court, Unit #15
Littleton, CO 80125
RE: The tariff classification of a backing plate adapter from Taiwan
Dear Mr. Wyche:
In your letter dated March 4, 2026, you requested a tariff classification ruling. Product information was
submitted with your request.
The item under consideration is a backing plate adapter which consists of a steel hex drive shaft and a steel
backing plate. You state that the two components will be imported together and are unassembled for shipping
efficiency. After importation, the hex drive shaft and backing plate will be combined into a finished backing
plate adapter by an orbital forming process. Based on the submitted information, this process involves the
application of pressure to the end of the hex drive shaft which passes through an opening in the backing plate.
Under pressure, the end of the hex drive flattens across the backing plate to form a permanent connection
between the two components. Aside from this assembly process, the functional physical characteristics of
both components, as imported, are unchanged.
After the pieces are connected, the backing plate adapter will be over-molded with foam and fitted with
hook-and-loop material to create a backing pad assembly. You state that the completed assembly is
specifically designed to hold 3-inch polishing, buffing, or abrasive discs for use with a hand-held power tool
such as a polisher or drill. Citing General Rule of Interpretation (GRI) 2(a) pertaining to unassembled
articles, you propose classification of the subject merchandise in heading 8467, Harmonized Tariff Schedule
of the United States (HTSUS). We agree.
The applicable subheading for the backing plate adapter will be 8467.99.0190, HTSUS, which provides for
“Tools for working in the hand, pneumatic, hydraulic or with self-contained electric or nonelectric motor, and
parts thereof: Parts: Other: Other.” The general rate of duty will be Free.
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
(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)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division