CLA-2-73:OT:RR:NC:N5:116
Ms. Eileni Rodriguez Gil
Metalum Fence and Supply
19200 SW 106TH Ave.
Miami, Florida 33157
RE: The tariff classification of welded tubes from Vietnam
Dear Ms. Rodriguez Gil:
In your letter dated April 6, 2026, you requested a tariff classification ruling.
The products to be imported are galvanized welded structural steel tubes of non-alloy steel, made to ASTM
A500 Standard, and manufactured in Vietnam. According to your submission, these products may be
imported either as galvanized steel tubing or pre-painted galvanized steel tubing. The
rectangular tubes measure 2"x1" and 24 feet in length, and the square tubes measure 2.5"x 2.5"and are 8
feet in length. They have a wall thickness ranging from 0.76 mm to 0.95 mm. You indicate the tubes serve as
structural framework of fences, onto which composite fence boards can be installed. The product is marketed
and sold as part of a residential fence system.
The applicable subheading for square and rectangular galvanized steel tubing (pre-painted or not) with a wall
thickness under 4 mm will be 7306.61.5000, Harmonized Tariff Schedule of the United States (HTSUS),
which provides for other tubes, pipes and hollow profiles (for example, open seamed or welded, riveted or
similarly closed), of iron or steel: Other, welded, of noncircular cross section: of square or rectangular cross
section: having a wall thickness of less than 4 mm: of iron or nonalloy steel. The rate of duty will be free.
Please be advised that the square tubes may be subject to antidumping duties and/or countervailing duties
(AD/CVD). Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and
Compliance office in the International Trade Administration of the Department of Commerce (ITA) and are
separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP). General
information regarding the ITA and AD/CVD can be found at
https://www.trade.gov/us-antidumping-and-countervailing-duties. The ITA’s “Guide on How to File for an
Antidumping/Countervailing Duty Scope Ruling Request” is available at
https://enforcement.trade.gov/scope/Request-Scope-Ruling.pdf.
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 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, contact
National Import Specialist Neil M. Cohen at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division