CLA-2-83:OT:RR:NC:N5:121
Kari Aiduk
Mohawk Global Logistics
123 Air Cargo Rd,
N. Syracuse, NY 13212
RE: The tariff classification of an aluminum bracket and ladder stabilizers from China
Dear Ms. Aiduk:
In your letter dated May 15, 2026, you requested a tariff classification ruling on behalf of Werner Co.
Photographs and descriptions of the merchandise were included in your inquiry.
The first article under consideration is described as a ladder jack, part number AC10-14-02. It is a triangular
shaped aluminum bracket with a clamping mechanism. The adjustable bracket is mounted vertically to an
extension ladder and functions to support and secure planks or platforms that are positioned between two
ladders.
The second article under consideration is described as a ladder stabilizer, part number AC96. It is a C-shaped
aluminum stabilizer that is mounted to the upper portion of an extension ladder. It functions to secure and
stabilize the ladder by distributing weight across a broader surface area and creating a stable interface
between the ladder and the supporting structure. The stabilizer provides a span of approximately 47 inches
and creates a standoff of approximately 10 inches from the contact surface.
The third article under consideration is described as a ladder stabilizer, part number AC78. This aluminum
stabilizer incorporates a spring-loaded locking mechanism that allows for quick installation and removal. It is
mounted to the upper portion of an extension ladder and functions to secure and stabilize the ladder by
securing its positioning and distributing weight relative to the supporting surface. The stabilizer provides a
span of approximately 44 inches and a standoff of approximately 10 inches.
In your letter, you propose classification of the ladder jack bracket and ladder stabilizers in subheading
8302.49.6085, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Base metal
mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork,
saddlery, trunks, chests, caskets or the like; …: Other mountings, fittings and similar articles, and parts
thereof: Other: Other: Other: Other. We disagree. As noted in Headquarters ruling 960428, the word
“fittings” is defined as “the fixtures and fitments of a building,” and the word “fixtures” as “something fixed
or fastened in position;” “articles attached to a house or land and regarded as legally part of it.” The ladder
jack bracket and ladder stabilizers are removable articles; they are not fixed in place and therefore they do not
meet the terms of heading 8302. Additionally, we note that the ladder jack bracket and ladder stabilizers are
used on a ladder. Ladders do not have the characteristics of and are not similar or akin to the articles
enumerated in the terms of heading 8302, namely furniture, doors, staircases, windows, blinds, coachwork,
saddlery, trunks, chests, and caskets. The ladder jack bracket and ladder stabilizers, therefore, are not suitable
for these articles and cannot be classified in subheading 8302.49 HTSUS.
It is our opinion that the ladder jack bracket is more specifically provided for in subheading 8302.50.0000,
HTSUS, which provides for Base metal hat racks, hat-pegs, brackets and similar fixtures. The Explanatory
Notes to the Harmonized Commodity Description and Coding System (ENs) represent 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. EN 8302 (G) states that 8302.50, HTSUS, covers
hat-racks, hat-pegs, brackets, and similar fixtures “such as coat racks, towel racks, dish-towel racks,
dish-cloth racks, brush racks, and key racks.” While the term “bracket” is not defined in either the HTSUS or
the Explanatory Notes, Webster’s Dictionary defines “bracket” as: “an overhanging member that projects
from a structure (such as a wall) and is usually designed to support a vertical load or to strengthen an angle.”
Additionally, the essential characteristics of items classified in 8302.50, HTSUS, are that they made of base
metal, are affixed to a wall, and function to hang, hold, or support items. Here, the subject aluminum ladder
jack bracket projects from a ladder and provides a mount that allows a plank or platform to sit vertically. It is
designed to support and hang a vertical load: the plank or platform. Based on the foregoing, we find that the
subject ladder jack bracket is described in subheading 8302.50.0000, HTSUS.
The applicable subheading for the ladder jack, part number AC10-14-02 will be 8302.50.0000, HTSUS,
which provides for Hat-racks, hat pegs, brackets and similar fixtures, and parts thereof. The general rate of
duty will be free.
Heading 7616, HTSUS, is a residual or basket provision which covers a wide range of aluminum articles that
are not more specifically provided for elsewhere in the HTSUS. The ENs to heading 7616 state that “This
heading covers all articles of aluminum other than those covered by the preceding headings of this Chapter,
or by Note 1 to Section XV, or articles specified or included in Chapter 82 or 83, or more specifically
covered elsewhere in the Nomenclature.” An article of aluminum can be classified in heading 7616 if it is
determined that the item is not more specifically provided for in any other heading of the tariff. The ladder
stabilizers, AC96 and AC78, are not specifically covered elsewhere in the tariff. Accordingly, they are
classifiable in heading 7616, HTSUS.
The applicable subheading for the ladder stabilizers, AC96 and AC78, will be 7616.99.5190, HTSUS, which
provides for “Other articles of aluminum: Other: Other: Other: Other: Other.” The general rate of duty will be
2.5 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 Jennifer Jameson at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division