The tariff classification of an aluminum hydroxide-based surface from Vietnam.

N357399May 29, 2026CLA-2-68:OT:RR:NC:N1:128
CATEGORY: Classification
TARIFF NO.: 6815.99.4170
Ms. Shu Ju ChiAgra Services Brokerage Co., Inc.221-20 147th AvenueJamaica, NY 11413RE: The tariff classification of an aluminum hydroxide-based surface from Vietnam.Dear Ms. Chi:In your letter dated
December 30, 2025
, you requested a tariff classification ruling on behalf of your client,Aurea Industrial Company Limited.The merchandise under consideration is referred to as style number CM1586QX. A sample was submittedwith your ruling request and was forwarded to the Customs and Border Protection Laboratory for analysis. This analysis has been completed. The CM1586QX is a polished, plain white surface which measures approximately 300 to 350 centimeterslong by 140 to 200 centimeters wide, and is between 1.2 to 3 centimeters thick. From the information youprovided, the surface is comprised of 45 to 55 percent by weight aluminum hydroxide, 3040 percent by to weight recycled glass granules, and 8 to 15 percent by weight polyester resin, with the balance provided bypigments and additives.The aluminum hydroxide component is a byproduct of industrial processes and is not naturally derived.After importation, the surface is cut to size and shape for such applications as countertops, shelving, and flooring.Laboratory analysis has determined that the aluminum hydroxide component provides the greatest part of theCM1586QX surface by weight.The CM1586QX surface is constructed of different materials that are classifiable in different headings.The classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) isgoverned by the General Rules of Interpretation (GRIs), taken in order.GRI 1 requires that classification be determined according to the terms of the headings and any relative section or chapter notes.In the event that goods cannot be classified solely on the basis of GRI 1, and if the heading and legal notes do not otherwiserequire, the remaining GRIs will be applied, in the order of their appearance.GRI 3(b) provides, in relevant
part, that composite goods which cannot be classified by reference to GRI 3(a) shall be classified as if theyconsisted of the material or component which gives them their essential character.The aluminum hydroxide component provides the essential character of this surface. The applicable subheading for the CM1586QX will be 6815.99.4170, HTSUS, which provides for “Articlesof stone or of other mineral substances…not elsewhere specified or included: Otherarticles: Other: Other: Other.” The general rate of duty will be Free. The duties cited above are current as of this ruling’s issuance. 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/.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties as provided for in Subchapter III to Chapter 99, HTSUS.Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies.The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Nicole Sullivan at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division