CLA-2-76:OT:RR:NC:N5:116
Mr. Alan R. Klestadt Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt, LLP 599 Lexington Avenue New York, New York 10022 RE: The tariff classification of aluminum shutters from Honduras Dear Mr. Klestadt: In your letter dated February 24, 2025, you requested a classification determination on behalf of your client, Extrum S.A. De C.V. The products under consideration are aluminum slats that are designed for use in the assembly of storm shutter systems. The shutter systems provide protection from inclement weather, such as hurricanes, hail, high winds, or flying debris. According to your submission, the slats will be imported with the frames to which they will be attached after importation. Prior to importation, the slats will be cut to customer-specific lengths, will be imported with either oblong holes or round holes, and can be either vented or non-vented. In addition to being cut to customer-specific lengths and having pre-drilled holes, the ends of the slats are rounded off and ready for immediate assembly into the finished storm shutter frames. The applicable subheading for the aluminum slats will be 7610.90.0080, 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: other: other: other. The rate of duty will be 5.7 percent ad valorem. On March 12, 2025, Presidential proclamation 10895 imposed additional tariffs on certain derivative aluminum products. Additional duties for derivative aluminum products of 25 percent are reflected in Chapter 99, headings 9903.85.04 and 9903.85.07. Products provided by heading 9903.85.08 will be subject to a duty of 25 percent upon the value of the aluminum content. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.85.07, in addition to subheading
7610.90.0080, HTSUS. Derivative aluminum articles processed in another country from aluminum articles that were smelted and cast in the United States, provided for in heading 9903.85.09, are not subject to the additional ad valorem duties. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. You should also be aware that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. 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