CLA-2-76:OT:RR:NC:N1:116
Mr. Nigel Spork
Centor North America Inc.
966-130 Corporate Blvd.
Aurora, IL 60502
RE: The tariff classification of aluminum extrusions from Poland
Dear Mr. Spork:
In your letter dated May 9, 2022, you requested a tariff classification ruling.
The products under consideration are identified as five types of aluminum extrusions/profiles made from type 6063 aluminum alloy. According to your submission, these extrusions will be imported in material lengths and will be used primarily in the manufacture of folding door and screen/shade systems for residential homes.
Part # STL-010, identified as “Stile common Al-Al”, is one of the vertical structural members of a door panel. This hollow profile has more than one enclosed void. It is comprised of two aluminum extrusions joined together with a pair of extruded polyamide plastic thermal break struts. Based on the information provided, the extrusions are knurled, assembled, crush rolled and cut-to-length. The polyamide thermal break struts act as an insulator which forms a barrier preventing the doors from icing. You state that the thermal break connection is by necessity structural and that STL-010 will be used to support the weight of adjacent panels.
Part # COV-024, described as “Cover suit jamb roll-end”, is an aluminum profile without an enclosed void (open profile) used in the manufacture of a Centor 405 folding door. This profile will be imported in bulk lengths of 2800 mm and after importation will be cut-to-length, machined, drilled, painted and assembled before it becomes part of the final door system.
Part # COV-104, identified as “Cover suit jamb screened S4”, is an open profile that will be manufactured for use as the inside face of the screen jamb and will become a component of the screen’s frame. This profile will be imported in bulk lengths of 2390 mm and 3170 mm in a plain “no finish” or a “natural anodized” finish. After importation, the COV-104 extrusion will undergo the following manufacturing operations: cutting-to-length, painting and assembly prior to becoming a part of the final screen system.
Part # SCC-232, described as “Roll tube aluminum 55 mm”, is hollow profile with one enclosed void. Although resembling a round tube, since the inner and outer surfaces are not of the same form, this product is considered a hollow profile for tariff purposes. You state the roll tube extrusion will be mounted vertically inside the left or right jamb to enable the screen/shade to be pulled horizontally across an opening. The SCC-232 extrusion will be imported in bulk lengths of 2450 mm and 3150 mm and after importation will be cut-to-length, drilled and assembled before becoming a part of the final screen system.
Part # HED-021, identified as “Head S4”, is an open profile that forms the upper part of the overall screen frame and is the main support track for the screen/shade fabric. This profile will be imported in bulk lengths of 3900 mm and 5800 mm in both a plain “no finish” and a “natural anodized” finish. After importation, the HED-021 extrusion will undergo the following manufacturing operations: cutting-to-length, machining, drilling, countersinking, painting and assembly prior to becoming a part of the final screen system.
You suggest classification of Part # STL-010 in subheading 7604.29.10, Harmonized Tariff Schedule of the United States (HTSUS), which provides for aluminum bars, rods and profiles: of aluminum alloys: other: other profiles. However, it is the opinion of this office that based on the method of manufacture, this component has been prepared for use in a structure, and therefore, is precluded from classification as an aluminum profile in heading 7604, HTSUS.
The applicable subheading for Part # STL-010, the dual profiles joined together by plastic break struts 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, 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.
You propose classification for Part #s COV-024, COV-104 and HED-021 in subheading 7604.29.1090, HTSUS, which provides for aluminum bars, rods and profiles: of aluminum alloys: other: other profiles: other. However, based on the chemistry submitted, we find that the profiles are more specifically provided for elsewhere in subheading 7604.29, HTSUS.
The applicable subheading for Part #s COV-024, COV-104 and HED-021 will be 7604.29.1010, HTSUS, which provides for aluminum bars, rods and profiles: of aluminum alloys: other: other profiles: heat-treatable industrial alloys of a kind described in statistical note 6 to this chapter. The rate of duty will be 5 percent ad valorem.
You suggest classification for Part # SCC-232 in subheading 7604.21.0090, HTSUS, which provides for aluminum bars, rods and profiles: of aluminum alloys: hollow profiles: other. However, based on the chemistry submitted, this office finds that the profiles are more specifically provided for elsewhere in subheading 7604.21, HTSUS.
The applicable subheading for Part # SCC-232 will be 7604.21.0010, HTSUS, which provides for aluminum bars, rods and profiles: of aluminum alloys: hollow profiles: heat-treatable industrial alloys of a kind described in statistical note 6 to this chapter. The rate of duty will be 1.5 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 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 7604.21.0010 and 7604.29.1010, 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