CLA-2-83:OT:RR:NC:N1:121
Mr. Steven R. Keller
Cascade Corporation
2201 NE 201st Ave.
Fairview, OR 97024-9718
RE: The tariff classification of an aluminum nameplate and stainless steel tacks from China
Dear Mr. Keller:
In your letter dated December 13, 2013, you requested a tariff classification ruling. The submitted samples will be retained by this office.
The merchandise under consideration is an aluminum nameplate, part number 903-004-4, and stainless steel tacks, part number 128-000-2. Both articles will be imported separately and are to be used on a Wedgelock Coupler, which is a part used primarily on heavy construction equipment to engage and disengage different digging or heavy equipment attachments by the operator in the cab of a truck or machine. You indicate that the nameplate will be affixed with the tacks onto the side of the Wedgelock Coupler and will serve to identify the product to the customer.
The nameplate, measuring 2-1/2 inches long by 2-1/4 inches wide, has an adhesive backing and a small hole at each corner. When imported, the plate portrays the CAT® brand logo, the name of the manufacturer (Caterpillar Inc.), the location of its headquarters (Peoria, IL, USA), and a seven digit serial number. It also contains the following words/abbreviations: “S/N,” “Model,” “Work Tool,” “kg,” “LB,” “L/min,” “gpm,” “kPa,” “psi,” and “Made In,” alongside spaces for recordation of the corresponding information. This additional information will be stamped on the nameplate in the importer’s U.S. facility.
Each hole on the nameplate accommodates a small tack. The tacks feature a flat, round head ranging in diameter from 3/16 inch to ¼ inch. The pointed shaft is available in lengths up to 1/8 inch. They serve to securely attach the nameplate to the Wedgelock Coupler. Although you refer to the tacks as “rivets” in your letter, because they do not deform when used, they are not classified as rivets for tariff purposes.
The applicable subheading for the aluminum nameplate will be 8310.00.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for sign plates, name plates, address plates and similar plates, numbers, letters and other symbols, and parts thereof, of base metal, excluding those of heading 9405. The rate of duty will be free.
The applicable subheading for the stainless steel tacks will be 7317.00.6560, HTSUS, which provides for nails, tacks, drawing pins, corrugated nails, staples (other than those of heading 8305) and similar articles, of iron or steel, whether or not with heads of other material, but excluding such articles with heads of copper: other: of one piece construction: other: other. The duty rate will be free.
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 on World Wide Web at http://www.usitc.gov/tata/hts/.
The aluminum nameplate and stainless steel tacks 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://addcvd.cbp.gov/.
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 Barbara Kaiser at (646) 733-3024.
Sincerely,
Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division