CLA-2-76:OT:RR:NC:N1:116
Ms. Jennifer Diaz
Diaz Trade Law
12700 Biscayne Boulevard, Suite 301
North Miami, Florida 33181
RE: The tariff classification of structures from Vietnam
Dear Ms. Diaz:
In your letter dated March 13, 2020, you requested a tariff classification ruling on behalf of your client, Containers Direct, LLC.
The products under consideration are screen doors, deck railing kits, fence kits, a louvered roof and a screen room. You indicate that these structures are comprised of aluminum extrusions made from aluminum alloy 6063 and 6005 and will be imported in both an assembled and unassembled condition. Representative pictures and diagrams were included in your request.
The screen doors, product number CD-SDP, consist of door frames and a door threshold made from fabricated aluminum extrusions, a bug screen, corner keys and steel screws. The extrusions are cut-to-length, machined, punched, drilled and painted and ready for final assembly.
The deck railing kits, product number CD-DRP, are comprised of a top rail, bottom rail, balusters and a deck railing post that is welded to a machined base plate. These components are made from fabricated aluminum extrusions that are cut-to-length, machined, punched, drilled and painted. The kits also include an aluminum casting top cap, and aluminum castings, and steel screws to mount the assembled railing section to the deck railing post. The top and bottom rails have holes drilled four inches apart for insertion of the balusters.
The fence kits, product number CD-FP, consist of rails, balusters, posts and gates that are made from fabricated aluminum extrusions. The extrusions have been cut-to-length, machined, punched, drilled and painted and are ready for final assembly. You indicate that steel screws are not included with the unassembled fence kits.
The louvered roof, product number CD-LRP, is comprised of roof blades, a structure frame and open/closed track extrusions. These components are made from fabricated aluminum extrusions that are cut-to-length, machined, punched, drilled and painted and ready for final assembly. You indicate that steel screws are not included with the unassembled louvered roof.
The screen room, product number CD-SRP, consists of roof beams, wall supports, gutters and door frames that are made from fabricated aluminum extrusions. The extrusions are cut-to-length, machined, punched, drilled and painted and ready for final assembly.
The applicable subheading for the screen door, whether assembled or unassembled, will be 7610.10.0030, Harmonized Tariff Schedule of the United States (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: other. The rate of duty will be 5.7 percent ad valorem.
The applicable subheading for the deck railing kits, fence kits, louvered roof and screen room, whether assembled or unassembled, will be 7610.90.0080, HTSUS, which provides for 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: other: other: other. The rate of duty will be 5.7 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 the 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 Angelia Amerson at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division