CLA-2-84:OT:RR:NC:N1:104
Ms. April J. Collier
Pacific Customs Brokers Inc.
1400 A Street
Blaine, WA 98230
RE: The tariff classification of a pump jack and a scaffolding pole from China
Dear Ms. Collier:
In your letter dated April 17, 2017, on behalf of Sky-Hi Industries, Inc., you requested a tariff classification ruling.
The pump jack and the scaffolding pole are components of a scaffolding system used for the purpose of manually raising and lowering planks up the side of an exterior wall to perform various construction tasks. An entire system is composed of a minimum two aluminum poles, each with its respecpective pump jack, a work bench and a roof brace. Components may be shipped all in one shipment or purchased separately. In your letter, you request a ruling on the pump jack and scaffolding pole when imported separately.
The pump jack is made of aluminum. You state that the jack’s foot step ‘allows the system to “climb” its way up a wall as it “bites” onto the rubber lining on the poles’.
The scaffolding pole is made of extruded aluminum, with a rubber and aluminum end cap. It features a rubber strip that is permanently affixed to the pole by gluing and riveting.
The applicable subheading for the pump jack will be 8425.49.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Pulley tackle and hoists other than skip hoists; winches and capstans; jacks: Jacks; hoists of a kind used for raising vehicles: Other”. The rate of duty will be Free.
The applicable subheading for the aluminum scaffolding pole will be 7610.90.0080, HTSUS, which provides for “Aluminum structures (excluding prefabricated buildings of heading 9406) and parts of structures (for example, bridges and bridge sections, lock gates, towers, lattice masts, roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, shutters, balustrades, pillars and columns); aluminum plates, rods, angles, shapes, sections, tubes and the like, prepared for use in structures: Other … Other: Other” . The rate of duty will be 5.7 percent ad valorem.
Aluminum extrusions, if manufactured in China, may be subject to antidumping duties or countervailing duties (AD/CVD). Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and Compliance office in the International Trade Administration of the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP). You can contact them at http://trade.gov/enforcement/ (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 https://www.usitc.gov (click on “Antidumping and Countervailing Duty” under “Popular Topics” at the top of the screen), and you can search AD/CVD deposit and liquidation messages using CBP’s AD/CVD Search tool at http://addcvd.cbp.gov/.
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 https://hts.usitc.gov/current.
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 Patricia O’Donnell at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division