CLA-2-73:OT:RR:NC:N1:113
Mr. Steve Weinberg
National Foundry Products
Address 111 West Mount Airy Avenue
Philadelphia, Pennsylvania 19119-2439
RE: The tariff classification of cast iron beam clamps from India, China and Vietnam
Dear Mr. Weinberg:
In your letter dated February 13, 2021, you requested a tariff classification ruling. Descriptions and pictures of the beam clamps were submitted with your letter for our review.
The subject articles are described as beam clamps that are made from malleable iron and larger sizes that may be made from ductile iron that will be imported as cast. The clamps are used in buildings to suspend pipes from ibeams. The suspended pipes may carry liquid or gas, or may be a conduit for electrical wiring. The clamps are primarily used in the plumbing and electrical industries. You stated in your letter that “Beam clamps are produced as sand castings – molten metal poured into sand molds. After cooling, the molds are broken up in a tumbling barrel and the parts separate from the gates and riser (the tree which carries the metal to each part). The malleable version is then annealed to obtain the right properties…beam clamps are sometimes also supplied in a ductile iron version which is also a cast part made with a slightly different chemical composition (primarily the addition of magnesium) and then left in the mold to obtain physical properties without having to separately anneal them.” At the time of import, the subject beam clamps will be cast and cleaned after removal from the sand casting mold. All of the finishing operations will be performed by the importer after importation into the United States.
The applicable subheading for the malleable cast iron beam clamps from India, China and Vietnam will be 7325.99.1000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other cast articles of iron or steel, other, other, of cast iron. The rate of duty will be free.
The applicable subheading for the nonmalleable (ductile) cast iron beam clamps from India, China and Vietnam will be 7325.10.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other cast articles of iron or steel, of nonmalleable cast iron, 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 on the World Wide Web at https://hts.usitc.gov/current.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 7325.99.1000 and 7325.10.0080, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 7325.99.1000 and 7325.10.0080, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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 Ann Taub at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division