CLA-2-83:OT:RR:NC:N1:102
Karl K Krueger
Radix Group International dba
DHL Global Forwarding
2660 20th Street
Port Huron, MI 48060
RE: The tariff classification of solar panel brackets from India.
Dear Mr. Krueger:
In your letter dated May 21, 2015 on behalf of PanelClaw Inc. you requested a tariff classification ruling. Samples were submitted with your letter and will be returned to you.
Part numbers 5000183XX and 5000184XX are support brackets comprised of galvanized steel. These brackets are used in a solar panel support system that keep solar panels stationary and set to the roof of a building. The support system consists of one of the instant supports and an additional support, the Claw, which attaches the solar panel to the instant support. Part numbers 5000183XX and 5000184XX contain pre-drilled holes that allow for cable management and recycled rubber pads that protect the roof. It is said that the supports can be imported in various configurations with regards to length and shape at the ends, however, the basic configuration remains constant. Each support bracket weighs less than 2.5 pounds.
Heading 8302 of the Harmonized Tariff Schedule of the United States (HTSUS) provides for base metal mountings, fittings and similar appliances suitable for buildings. Headquarters Ruling 966458, dated June 19, 2003, describes a mounting of Heading 8302 as something that serves as a backing, support, setting, etc.
The instant brackets are part of a support system that enable solar panels to be set on the roof of a building. As such, the applicable subheading for the support brackets, part numbers 5000183XX and 5000184XX will be 8302.41.6080, HTSUS, which provides for base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds coachwork….suitable for buildings; Other; Of iron or steel, of aluminum or of zinc; Other. The duty rate is 3.9 percent ad valorem.
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/.
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 Sandra Martinez at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division