CLA-2-73:OT:RR:NC:N4:422
Ms. Lisa Leven
Bill Rawls LLC
3600 Eldorado Parkway, Building C, Suite 3
McKinney, TX 75070
RE: The tariff classification of an iron pedestal bowl from India
Dear Ms. Leven:
In your letter dated April 1, 2025, you requested a tariff classification ruling. Photographs of the item were
submitted along with your request.
The merchandise under consideration is an iron pedestal bowl, model number: AH-DG-PD-01. A pedestal
supports the circular iron blue bowl, which is available in small and large sizes. The small bowl measures
approximately 7.5 inches wide by 7.5 inches deep by 2.95 inches high. The large bowl measures
approximately 9.25 inches wide by 9.25 inches deep by 3.58 inches high.
You have indicated that the items will be sold separately and that the bowl is intended for home use and is
unsafe for food contact. You refer to the circular blue pedestal bowl as a tray. However, a tray is an open
receptacle wide enough to support and carry dishes, plates, bowls, and drinking vessels, which in turn, hold
and serve food and beverages. Therefore, this item is not a tray, but a bowl.
The applicable subheading for the iron pedestal bowl, model number: AH-DG-PD-01, will be 7323.99.9080,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Table, kitchen or other
household articles and parts thereof, of iron or steel; Other: Other: Not coated or plated with precious metal:
Other: Other. Other.” The rate of duty will be 3.4 percent ad valorem.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other
countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must
report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to
subheading 7323.99.9080, HTSUS, listed above.
You inquired whether the Section 232 additional duties on certain derivative steel products applies to the iron
pedestal bowl, model number: AH-DG-PD-01.?Articles of subheading 7323.99.9080, HTSUS, are not among
those listed in Annex 1 to Presidential Proclamation 10896.
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products.? Additional duties for derivative iron or steel products of 25 percent are reflected in Chapter
99, headings 9903.81.89 and 9903.81.90.? Products provided by heading 9903.81.91 will be subject to a duty
of 25 percent upon the value of the steel content.? At the time of entry, you must report the Chapter 99
heading applicable to your product classification, i.e. 9903.81.90, in addition to subheading 7323.99.9080,
HTSUS.? Derivative iron or steel products processed in another country from steel articles melted and poured
in the United States,?provided for in heading 9903.81.92, are not subject to the additional ad valorem duties. ?
Please note that derivative 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 9903.81.93, HTSUS.
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/.
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 and Border Protection
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, please contact
National Import Specialist Dana L. Giammanco at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division