CLA-2-76:OT:RR:NC:N5:116
Ms. Jamie Palios
ITOCHU International Inc.
1251 Avenue of the Americas
New York, New York 10020
RE: The tariff classification of aluminum alloy profiles, fittings, and tubes from Taiwan.
Dear Ms. Palios:
In your letter dated May 19, 2026, you requested a tariff classification ruling. No samples were included with
your submission.
Item 1, part number ADA-RR, is described as a 180-degree loop return made of aluminum alloy. This bent
tube is a hollow curved portion of railing that connects to a railing post with a bracket.
Item 3, part number ADA-CR, is described as a kit which includes a 90-degree corner piece (elbow), two
joiner pieces, two circular collars, all made of aluminum alloy and packed together in a singular clear bag. It
is said in your submission, the two circular collars allow the joint to be covered for a more seamless
appearance.
Item 4, part number ADA-JK, is described as an internal joiner made from type 6005-T5 aluminum alloy.
This C-shaped aluminum profile is used to seamlessly connect two railing sections together with 4 screws.
You propose classification of the 180-degree Loop Return, 90-degree Corner w/ 2 Joiner 8 Screws, and the
Joiner Kit 4 Screws 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: Of iron or steel, of aluminum or of zinc: Other: Other. This
office disagrees. When interpreting and implementing the HTSUS, the ENs of the Harmonized Commodity
Description and Coding System may be used. The ENs, while neither legally binding nor dispositive, provide
a guiding commentary on the scope of each heading, and are generally indicative of the proper interpretation
of the HTSUS. CBP believes the ENs should always be consulted. See T.D. 89-80, 54 Fed. Reg. 35127,
35128 (August 23, 1989). The ENs to heading 8302 state: “This heading covers general purpose classes of
base metal accessory fittings and mountings, such as are used largely on furniture, doors, windows,
coachwork, etc. Goods within such general classes remain in this heading even if they are designed for
particular uses (e.g., door handles or hinges for automobiles). The heading does not, however extend to goods
forming an essential part of the structure of the article, such as window frames or swivel devices for
revolving chairs.” It is our opinion that these articles function to join together to create the railing. Therefore,
these articles are excluded from classification under heading 8302.
The applicable subheading for Item 1, part number ADA-RR, 180-degree loop return will be 7608.20.0030,
HTSUS, which provides aluminum tubes and pipes: of aluminum alloys: seamless. The rate of duty will be
5.7 percent ad valorem.
The applicable subheading for the kit, Item 3, part number ADA-CR with a 90-degree corner piece, two
joiner pieces, two circular collars, of which the essential character is imparted by the elbow will be
7609.00.0000, HTSUS, which provides for aluminum tube or pipe fittings (for example, couplings, elbows,
sleeves). The rate of duty will be 5.7 percent ad valorem.
The applicable subheading for Item 4, part number ADA-JK, C-shaped aluminum joiner pieces will be
7604.29.1010, HTSUS, which provides for aluminum bars, rods and profiles, of aluminum alloys, hollow
profiles. The rate of duty will be 1.5 percent ad valorem.
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/current.
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