The tariff classification of various brushes from China.
Issued June 29, 2020 by U.S. Customs and Border Protection.
Tariff classification
HTS codes: 9603.90.8050, 9903.88.15
Product description
A product catalog and images were submitted in lieu of samples. You indicate all of the below brushes can be used either by itself or connected to a telescopic pole. The first brush under consideration is described as an “aluminum-back brush.” The brush has a die-cast aluminum back and handle, with an aluminum channel set on a backing of polyvinyl chloride (PVC). It has a curved-body design with mar-poof end caps. The bristles are made from nylon. Your submission indicates this brush can be used on multiple surfaces. The second brush under consideration is described as a “flexible body brush.” The brush has a die-cast aluminum handle and features an extra-wide width body. The product catalog indicates the bristles of this brush are made either from nylon or polypropylene. Your submission indicates this brush can be used on multiple surfaces. The third brush under consideration is described as an “ultra-curve brush.” The brush has a die-cast aluminum back and handle and features a curve-body design. The bristles are made from nylon. Your submission indicates this brush can be used on multiple surfaces. The fourth brush under consideration is described as an “aluminum-back algae brush.” The brush has a die-cast aluminum back and handle and has either a curve or flat body design. The bristles are made from stainless steel. Your submission indicates this brush can be used on multiple surfaces, except vinyl or easy to scratch surfaces. The fifth brush under consideration is described as an “aluminum-back combo-bristle brush.” The brush has a die-cast aluminum back and handle and features a curve-body design. The bristles are made from a combination of stainless steel and nylon. Your submission indicates this brush can be used on multiple surfaces, except vinyl or easy to scratch surfaces.
CBP rationale
The applicable subheading for these brushes will be 9603.90.8050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[b]rooms, brushes (including brushes constituting parts of machines, appliances or vehicles), hand-operated mechanical floor sweepers, not motorized, mops and feather dusters; prepared knots and tufts for broom or brush making; paint pads and rollers; squeegees (other than roller squeegees): [o]ther: [o]ther: [o]ther.
Full text
N312793 June 29, 2020 CLA-2-96:OT:RR:NC:N4:415 CATEGORY: Classification TARIFF NO.: 9603.90.8050; 9903.88.15 Ms. Giuliana Esparta Poolmaster, Inc. 770 Del Paso Road Sacramento, CA 95834 RE: The tariff classification of various brushes from China. Dear Ms. Esparta: In your letter dated June 25, 2020, you requested a tariff classification ruling. A product catalog and images were submitted in lieu of samples. You indicate all of the below brushes can be used either by itself or connected to a telescopic pole. The first brush under consideration is described as an “aluminum-back brush.” The brush has a die-cast aluminum back and handle, with an aluminum channel set on a backing of polyvinyl chloride (PVC). It has a curved-body design with mar-poof end caps. The bristles are made from nylon. Your submission indicates this brush can be used on multiple surfaces. The second brush under consideration is described as a “flexible body brush.” The brush has a die-cast aluminum handle and features an extra-wide width body. The product catalog indicates the bristles of this brush are made either from nylon or polypropylene. Your submission indicates this brush can be used on multiple surfaces. The third brush under consideration is described as an “ultra-curve brush.” The brush has a die-cast aluminum back and handle and features a curve-body design. The bristles are made from nylon. Your submission indicates this brush can be used on multiple surfaces. The fourth brush under consideration is described as an “aluminum-back algae brush.” The brush has a die-cast aluminum back and handle and has either a curve or flat body design. The bristles are made from stainless steel. Your submission indicates this brush can be used on multiple surfaces, except vinyl or easy to scratch surfaces. The fifth brush under consideration is described as an “aluminum-back combo-bristle brush.” The brush has a die-cast aluminum back and handle and features a curve-body design. The bristles are made from a combination of stainless steel and nylon. Your submission indicates this brush can be used on multiple surfaces, except vinyl or easy to scratch surfaces. The applicable subheading for these brushes will be 9603.90.8050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[b]rooms, brushes (including brushes constituting parts of machines, appliances or vehicles), hand-operated mechanical floor sweepers, not motorized, mops and feather dusters; prepared knots and tufts for broom or brush making; paint pads and rollers; squeegees (other than roller squeegees): [o]ther: [o]ther: [o]ther.” The column one, general rate of duty is 2.8% ad valorem. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9603.90.8050, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 9603.90.8050, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china respectively. 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. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR 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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