CLA-2-72:OT:RR:NC:N5:117
Jaqui Lawhead Boise Cascade 1111 W. Jefferson Street, Suite 300 Boise, ID 83702 RE: The tariff classification of rebar pins from China Dear Ms. Lawhead: In your letter dated March 3, 2025, you requested a tariff classification ruling. The products under consideration are identified as rebar pins. The nonalloy steel rebar measures ½ inch in diameter and is cut into 1 to 4-foot lengths. The applicable subheading for the rebar pins will be 7214.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other bars and rods of iron or nonalloy steel, not further worked than forged, hot-rolled, hot-drawn or hot-extruded, but including those twisted after rolling: Concrete reinforcing bars and rods. The rate of duty will be free. On March 12, 2025, Presidential proclamations 10895 and 10896 imposed additional tariffs on products of steel and aluminum. Additional duties for steel and aluminum products of 25 percent are reflected in Chapter 99, heading 9903.81.87 for steel and heading 9903.85.02 for aluminum. Products classified under subheading 7214.20.0000, HTSUS, may be subject to additional duties. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.81.87, in addition to the Chapter 72, 73 or 76 subheadings listed above. Please note that steel products admitted to a U.S. foreign trade zone under “privileged foreign status” before March 12, 2025, and entered for consumption on or after March 12, 2025, may be subject to additional duties under heading 9903.81.88, HTSUS. Pursuant to U.S. Note 31(b) to Subchapter III, Chapter 99, HTSUS, effective September 27, 2024, products of China classified under subheading 7214.20.0000, HTSUS, unless specifically excluded, are subject to an additional 25% ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.91.01, in addition to subheading 7214.20.0000, HTSUS, listed above.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition to subheading 7214.20.0000, HTSUS, listed above. Please be advised that the rebar pins may be subject to AD/CVD. Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and Compliance office in the International Trade Administration of the Department of Commerce (ITA) and are separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP). General information regarding the ITA and AD/CVD can be found at https://www.trade.gov/us-antidumping-and-countervailing-duties. The ITA?s ?Guide on How to File for an Antidumping/Countervailing Duty Scope Ruling Request? is available at https://enforcement.trade.gov/scope/Request-Scope-Ruling.pdf. 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. 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. Additionally, we note 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 Denise Hopkins at [email protected].
Sincerely,
Steven A. Mack Director National Commodity Specialist Division