CLA-2-73:OT:RR:NC:N1:116
Ms. Yesenia Gallegos
Technical Glass Products, Inc.
8107 Bracken Place SE
Snoqualmie, Washington 98065
RE: The tariff classification of hollow profiles from Germany
Dear Ms. Gallegos:
In your letter dated June 18, 2020, you requested a tariff classification ruling.
The products under consideration are welded nonalloy steel hollow profiles. According to your submission, these hot-dipped galvanized profiles will be imported in 6 meter lengths and will be used in the manufacture of fire rated windows, doors and their frames.
Item # RP1856CA is a “pi” shaped (or T-shaped) hollow profile with a uniform cross section along its entire length and more than one enclosed void. This profile has a non-circular, non-square or non-rectangular cross section with a wall thickness of 2 mm.
Item # RP1833CA is a hollow profile with a square shaped enclosed void. The profile measures 50 mm x 50 mm and has a “tail” or appendage measuring 20 mm and a wall thickness of 1.5 mm. Although resembling a square tube, since the inner and outer surfaces are not of the same form, this product is considered a hollow profile for tariff purposes.
Item # RP9300CA is comprised of 3 hollow profiles which you state are “welded together with rods that penetrate the three hollows to hold the profiles together” and contain fire insulation. The profiles have a wall thickness of 1.8 mm. You indicate that two of the three profiles have a non-square, non-rectangular, non-circular cross section and that the third profile has a rectangular cross section. In between each profile is an insulation board which is fire protective material made of calcium silicate. The insulation is attached to the profiles with adhesive.
The applicable subheading for Item #s RP1856CA and RP1833CA will be 7306.69.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other tubes, pipes and hollow profiles (for example, open seamed or welded, riveted or similarly closed), of iron or steel: other, welded, of noncircular cross section: of other noncircular cross section: having a wall thickness of less than 4 mm: of iron or nonalloy steel. The rate of duty will be free.
The applicable subheading for Item # RP9300CA will be 7308.90.9590, HTSUS, which provides for 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) of iron or steel; plates, rods, angles, shapes, sections, tubes and the like, prepared for use in structures, of iron or steel: other: other: other: other: other. The rate of duty 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 at https://hts.usitc.gov/current.
On March 8, 2018, Presidential proclamations 9704 and 9705 imposed additional tariffs and quotas on a number of steel and aluminum mill products. Exemptions have been made on a temporary basis for some countries. Quantitative limitations or quotas may apply for certain exempted countries and can also be found in Chapter 99. Additional duties for steel of 25 percent and for aluminum of 10 percent are reflected in Chapter 99, subheading 9903.80.01 for steel and subheading 9903.85.01 for aluminum. Products classified under subheading 7306.69.5000, HTSUS, may be subject to additional duties or quota. At the time of importation, you must report the Chapter 99 subheading applicable to your product classification in addition to the Chapter 72, 73 or 76 subheading listed above.
The Proclamations are subject to periodic amendment of the exclusions, so you should exercise reasonable care in monitoring the status of goods covered by the Proclamations and the applicable Chapter 99 subheadings.
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