CLA-2-39:S:N:N3D:221 879329
Mr. Jim Reynolds
John A. Steer Co.
28 S. Second Street
Philadelphia, PA 19106
RE: The tariff classification of suspended ceiling systems from
Belgium.
Dear Mr. Reynolds:
In your letter dated October 19, 1992, on behalf of Rulon
Company, you requested a tariff classification ruling.
The ceiling system consists of polyvinyl chloride (PVC)
sections and various components, among them stainless steel
carriers that have holes and slots. The pictures of the PVC
sections that you provided indicate that these sections have a
uniform cross section along their entire length. The PVC
sections fall into two general categories: those with a circular
cross section, such as the "Curved Face Spacer," and those with
more complex cross sections, such as the "Deep Straight Edge
Strip," the "Curved Edge Strip," the "Perimeter Wall Trim," the
"Carrier Connector" and the "Flat Faced Spacers." The systems
will be imported either as complete units or as separate
components. The method of importation will affect the
classification. Classification of the PVC sections is dependent
on whether they have been further worked. Drilling holes into
the PVC sections prior to importation is an example of further
working. Though there is no mention of any further working on
the PVC sections, and no such processing is visible in your
submitted illustrations, classification for sections which have
been further worked is provided for your information.
The applicable subheading for the PVC ceiling system
including all its components, when imported as an unassembled
unit, will be 3925.90.0000, Harmonized Tariff Schedule of the
United States (HTS), which provides for builders' ware of
plastics, not elsewhere specified or included, other. The rate
of duty will be 5.3 percent ad valorem.
The applicable subheading for the "Curved Face Spacer,"
whether or not further worked, when not imported as part of an
unassembled unit, will be 3925.90.0000, Harmonized Tariff
Schedule of the United States (HTS), which provides for builders'
ware of plastics, not elsewhere specified or included, other.
The rate of duty will be 5.3 percent ad valorem.
The applicable subheading for the PVC sections with a
uniform cross section more complex than merely circular, when not
further worked and not imported as part of an unassembled unit,
will be 3916.20.0090, HTS, which provides for sticks and profile
shapes, whether or not surface-worked but not otherwise worked,
of plastics, of polymers of vinyl chloride.
The applicable subheading for the PVC sections with a
uniform cross section more complex than merely circular, when
further worked and not imported as part of an unassembled unit,
will be 3925.90.0000, HTS, which provides for builders' ware of
plastics, not elsewhere specified or included, other. The rate
of duty will be 5.3 percent ad valorem.
The applicable subheading for the stainless steel carrier,
when not imported as part of an unassembled unit, will be
7222.40.6000, HTS, which provides for angles, shapes and sections
of stainless steel, other. The rate of duty will be 5.3 percent
ad valorem.
Your letter does not provide enough information for us to
issue a ruling for the metal carriers and "Quick Action Hangers"
when they are not imported as part of an unassembled unit.
Before we can classify the metal carriers, we need to know the
type of metal. If of steel, please provide a mill certificate
showing the chemical composition or grade of steel. In addition,
state the materials of which Quick-Action Hangers are composed.
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
transaction.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport