CLA-2-76:OT:RR:NC:N1:117
Mr. Bo James
Lisa Ragan Customs Brokerage
1 Clay Pl.
Hapeville, GA 30354
RE: The tariff classification of an aluminum inswing door sill from China
Dear Mr. James:
In your letter dated August 31, 2017, you requested a tariff classification ruling on behalf of your client, Global Products International Group. A representative sample was submitted with your request and will be returned to you under separate cover.
The item under consideration is an inswing door sill for use in residential homes or commercial properties. The door sill, which measures 32 inches in length, is a composite good consisting of an extruded aluminum plate made from 6063 T-6 alloy aluminum, a PVC base, a PVC back and a PVC cap and includes four steel/zinc plated adjustable screws.
Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is in accordance with the General Rules of Interpretation (GRIs). GRI 3(b) provides that mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale shall be classified as if they consisted of the material or component which gives them their essential character, which may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the article.
You suggest classification of the inswing door sill in subheading 3925.20.0091, HTSUS, which provides for Builders’ ware of plastics, not elsewhere specified or included: Doors, windows and their frames and thresholds for doors, Other. Based on the submitted documentation, the sill’s plastic components clearly predominate by weight and value. However, it is the aluminum portion that comprises the greatest surface area, provides the greatest visual impact and plays the most significant role. The strength of the aluminum permits it to provide a secure bottom piece to the doorway and to support those who may pass over it, upon entry or exit. As such, we find that the plastic components do not impart the essential character to the inswing door sill and classification within Chapter 39, as an article of plastic, is precluded.
The applicable subheading for the aluminum inswing door sill will be 7610.10.0020, HTSUS, which provides for aluminum structures (excluding prefabricated buildings of heading 9406) and parts of structures (for example, bridges and bridge-sections, towers, lattice masts, roofs, roofing
frameworks, doors and windows and their frames and thresholds for doors, balustrades, pillars and columns), aluminum plates, rods, profiles, tubes and the like, prepared for use in structures, doors, windows and their frames and thresholds for doors, thresholds for doors. The rate of duty will be 5.7 percent ad valorem.
Please be advised that the aluminum inswing door sill 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 Mary Ellen Laker at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division