OT:RR:NC:N4:N4:422
Victor Saucedo
Monte Grande
Calle Candilejas 3
Salvador Escalante 61800
Mexico
RE: The eligibility under the United States-Mexico-Canada Agreement (USMCA) of copper and brass
kitchen and bathroom sinks from Mexico
Dear Mr. Saucedo:
In your letter dated July 15, 2026, you requested a binding ruling on the tariff classification and eligibility of
kitchen and bathroom sinks under the United States-Mexico-Canada Agreement (USMCA). Photographs
were submitted along with your request.
The subject merchandise are copper and brass kitchen and bathroom sinks. The finished sinks are intended
for residential or commercial kitchen use and residential bathroom use. The copper and brass sinks are
imported as finished articles ready to be installed into or onto kitchen countertops, bathroom vanities,
cabinets, or other supporting surfaces.
Item 1 is a copper kitchen sink. The rectangular-shaped sink is made of 100% copper. The item measures
approximately 33 inches long by 22 inches wide by 9 inches deep. The copper sink contains a drain opening
of approximately 3.50 inches in diameter.
Item 2 is a copper kitchen sink. The rectangular-shaped sink is made of 100% copper. The item measures
approximately 33 inches long by 22 inches wide by 9 inches deep. The copper sink contains a drain opening
of approximately 3.50 inches in diameter.
Item 3 is a copper bathroom sink. The circular-shaped sink is made of 100% copper. The item measures
approximately 16 inches long by 12 inches wide by 4.50 inches deep. The copper sink contains a drain
opening of approximately 1.80 inches in diameter.
Item 4 is a brass kitchen sink. The rectangular-shaped sink is made of 100% brass. The item measures
approximately 33 inches long by 22 inches wide by 9 inches deep. The brass sink contains a drain opening of
approximately 3.50 inches in diameter.
Item 5 is a brass bathroom sink. The circular-shaped sink is made of 100% brass. The item measures
approximately 16 inches long by 12 inches wide by 4.50 inches deep. The brass sink contains a drain opening
of approximately 1.50 inches in diameter.
Classification:
The applicable subheading for Item 1, the copper kitchen sink, Item 2, the copper kitchen sink, and Item 3,
the copper bathroom sink will be 7418.20.5000, Harmonized Tariff Schedule of the United States (HTSUS),
which provides for “Table, kitchen or other household articles and parts thereof, of copper; pot scourers and
scouring or polishing pads, gloves and the like, of copper; sanitary ware and parts thereof, of copper: Sanitary
ware and parts thereof: Other.” The general rate of duty will be 3 percent ad valorem.
The applicable subheading for Item 4, the brass kitchen sink and Item 5, the brass bathroom sink will be
7418.20.1000, HTSUS, which provides for “Table, kitchen or other household articles and parts thereof, of
copper; pot scourers and scouring or polishing pads, gloves and the like, of copper; sanitary ware and parts
thereof, of copper: Sanitary ware and parts thereof: Of copper-zinc base alloys (brass).” The general rate of
duty will be 3 percent ad valorem.
Facts:
The raw materials and components are sourced as follows:
100% copper sheet: Mexico
100% brass sheet: Mexico
All the manufacturing processes performed in Mexico are as follows:
The copper or brass sheet is traced and cut to the required dimensions.
The copper or the brass is manually hammered and formed.
The formed copper or brass components are assembled and permanently joined by welding.
Once the body of the sink has been completed, a drain opening is made in the center of the sink.
The finished sink is patinated using heat and fire to obtain the desired surface appearance.
The sink is cleaned, inspected, detailed, packed, and exported to the United States.
USMCA:
The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30,
2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the
USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note (“GN”)
11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is
an originating good for purposes of the USMCA. GN 11(b) states:
For the purposes of this note, a good imported into the customs territory of the United States from the
territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff
treatment provided for in the applicable subheading and quantitative limitations set forth in the tariff schedule
as a “good originating in the territory of a USMCA country” only if-
(i) the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries;
(ii) the good is a good produced entirely in the territory of one or more USMCA countries, exclusively from
originating materials;
(iii) the good is a good produced entirely in the territory of one or more USMCA countries using
non-originating materials, if the good satisfies all applicable requirements set forth in this note (including the
provisions of subdivision (o));
The copper and brass kitchen and bathroom sinks qualify for USMCA upon compliance with all applicable
laws, regulations, and agreements.
Based on the facts provided, the copper and brass kitchen and bathroom sinks qualify for USMCA
preferential treatment, because they are considered a good wholly obtained or produced entirely in a USMCA
country under General Note 11(b) (i). The goods will, therefore, be entitled to a free rate of duty under the
USMCA upon compliance with all applicable laws, regulations, and agreements.
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 Dana L. Salas at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division