CLA-2-76:OT:RR:NC:N1:113

Mr. Matthew Robinson
Summit Treestands, LLC
715 Summit Drive SE
Decatur, AL 35601

RE: The tariff classification of an aluminum subassembly from China

Dear Mr. Robinson:

In your letter dated October 28, 2010, you requested a tariff classification ruling on an aluminum subassembly. Marketing literature for the Summit Titan Climbing Tree Stand, and specification sheets for the Titan Platform Assembly and Subassembly were submitted for our review.

The subject merchandise is identified in your letter as an aluminum subassembly, model number 81087. You state in your letter that “The subassembly in question currently is used as a standing platform portion of a suspended structure used for hunting recreational purposes. The imported subassembly would be attached to a welded assembly.” The imported subassembly will be subject to further processes in the United States. These processes include welding the imported subassembly to a domestically produced subassembly for use in a final weldment for a deer stand platform. You also state that “Currently this product is being 100 percent made in the USA. We are considering having this piece made in China.”

The merchandise in question may be subject to antidumping duties or countervailing duties. Written decisions regarding the scope of AD/CVD orders are issued by the Import Administration in the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs and Border Protection. You can contact them at http://www.trade.gov/ia/ (click on “Contact Us”). For your information, you can view a list of current AD/CVD cases at the United States International Trade Commission website at http://www.usitc.gov (click on “Antidumping and countervailing duty investigations”), and you can search AD/CVD deposit and liquidation messages using the AD/CVD Search tool at http://www.cbp.gov (click on “Import” and “AD/CVD”).

The applicable subheading for the aluminum subassembly, model number 81087, will be 7616.99.5090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of aluminum, other…other. The general rate of duty will be 2.5 percent ad valorem.

Duty rates are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Ann Taub at 646-733-3018.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division