CLA-2-76:OT:RR:NC:N5:463
Jill Cramer
Mowry & Grimson, PLLC
5335 Wisconsin Ave., NW, Suite 810
Washington, DC 20015
RE: The tariff classification of an adjustable aluminum door sill from South Korea
Dear Ms. Cramer:
In your letter dated May 29, 2026, you requested a tariff classification ruling on behalf of your client,
Composite Technology International, Inc. (“CTI”). Illustrative literature, product descriptions and a bill of
materials were provided with your request.
The subject merchandise, the adjustable aluminum door sill, is a composite good consisting of an aluminum
deck, a PVC adjustable top cap, a PVC side cap, a PS substrate base, and steel screws.
Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is in
accordance with the General Rules of Interpretation (GRIs). GRI 3(b) provides that mixtures, composite
goods consisting of different materials or made up of different components, and goods put up in sets for retail
sale shall be classified as if they consisted of the material or component which gives them their essential
character, which may be determined by the nature of the material or component, its bulk, quantity, weight or
value, or by the role of a constituent material in relation to the use of the article.
You suggest classification of the adjustable door sill in subheading 3925.20.0091, HTSUS, which provides
for Builders’ ware of plastics, not elsewhere specified or included: Doors, windows and their frames and
thresholds for doors, Other. Based on the submitted documentation, the sill’s plastic components
predominate by weight and value. However, it is the aluminum portion that comprises the greatest surface
area, provides the greatest visual impact and plays the most significant role. As such, we find that the plastic
components do not impart the essential character to the adjustable door sill and classification within Chapter
39, as an article of plastic, is precluded. Further, this product is similar to the product in NY Ruling N289949
dated September 29, 2017 which was classified in subheading 7610.10.0020, HTSUS.
The applicable subheading for the aluminum adjustable door sills will be 7610.10.0020, HTSUS, which
provides for aluminum structures (excluding prefabricated buildings of heading 9406) and parts of structures
(for example, bridges and bridge-sections, towers, lattice masts, roofs, roofing
frameworks, doors and windows and their frames and thresholds for doors, balustrades, pillars and columns),
aluminum plates, rods, profiles, tubes and the like, prepared for use in structures, doors, windows and their
frames and thresholds for doors, thresholds for doors. The general rate of duty will be 5.7 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 ChingJu (Claudia) Lin at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division