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The tariff classification of plastic and rubber pattern letters from an unspecified country.
Issued November 19, 2018 by U.S. Customs and Border Protection.
Cite this ruling
Copies to clipboardN3 N301504 (November 19, 2018)
Tariff classification
HTS codes: 4016.99.6050, 3926.90.9990
Product description
The subject merchandise consists of two versions of pattern letters, which are utilized for a wide range of applications throughout the pattern and foundry industries. The first type is made from injection-molded plastic. Generally, they are applied to the pattern or corebox and are used to identify the company name, part number, and date code. The second type is constructed from rubber. They are flexible, easy to change, and snap in or out of the rubber holder that keeps the letters aligned. They can be used in applications where temperatures do not exceed 200 degrees Fahrenheit. Both styles consist of various sizes containing letters, numbers, and symbols.
CBP rationale
The applicable subheading for the plastic pattern letters, will be 3926.90.9990, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther. The applicable subheading for the rubber pattern letters will be 4016.99.6050, HTSUS, which provides for “[o]ther articles of vulcanized rubber other than hard rubber: [o]ther: [o]ther: [o]ther: [o]ther: [o]ther: [o]ther.
Full text
N301504 November 19, 2018 CLA-2-39:OT:RR:NC:N4:415 CATEGORY: Classification TARIFF NO.: 3926.90.9990; 4016.99.6050 Mr. Ben Inman Freeman Manufacturing & Supply Company 1101 Moore RoadAvon, OH 44011 RE: The tariff classification of plastic and rubber pattern letters from an unspecified country. Dear Mr. Inman: In your letter dated October 31, 2018, you requested a tariff classification ruling. The subject merchandise consists of two versions of pattern letters, which are utilized for a wide range of applications throughout the pattern and foundry industries. The first type is made from injection-molded plastic. Generally, they are applied to the pattern or corebox and are used to identify the company name, part number, and date code. The second type is constructed from rubber. They are flexible, easy to change, and snap in or out of the rubber holder that keeps the letters aligned. They can be used in applications where temperatures do not exceed 200 degrees Fahrenheit. Both styles consist of various sizes containing letters, numbers, and symbols. The applicable subheading for the plastic pattern letters, will be 3926.90.9990, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther.” The column one, general rate of duty is 5.3 percent ad valorem. The applicable subheading for the rubber pattern letters will be 4016.99.6050, HTSUS, which provides for “[o]ther articles of vulcanized rubber other than hard rubber: [o]ther: [o]ther: [o]ther: [o]ther: [o]ther: [o]ther.” The column one, general rate of duty is 2.5 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. Your letter does not indicate the pattern letters’ country of origin. In the event China is determined to be the country of origin, please be advised of the following: Effective July 6, 2018, the Office of the United States Trade Representative (USTR) imposed an additional tariff on certain products of China classified in the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(b), HTSUS. The USTR imposed additional tariffs, effective August 23, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(d), HTSUS. Subsequently, the USTR imposed further tariffs, effective September 24, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(f) and U.S. Note 20(g), HTSUS. For additional information, please see the relevant Federal Register notices dated June 20, 2018 (83 F.R. 28710), August 16, 2018 (83 F.R. 40823), and September 21, 2018 (83 F.R. 47974). Products of China that are provided for in subheading 9903.88.01, 9903.88.02, 9903.88.03, or 9903.88.04 and classified in one of the subheadings enumerated in U.S. Note 20(b), U.S. Note 20(d), U.S. Note 20(f) or U.S. Note 20(g) to subchapter III shall continue to be subject to antidumping, countervailing, or other duties, fees and charges that apply to such products, as well as to those imposed by the aforementioned Chapter 99 subheadings. Products of China classified under subheading 4016.99.60, HTSUS, unless specifically excluded, are subject to the additional 10 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 4016.99.6050, HTSUS, listed above. The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading. 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 Kristopher Burton at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division
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