RE: The tariff classification of solder powder from Japan

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N359194 August 31, 2026 CLA-2-71:OT:RR:NC:N1:126 CATEGORY: Classification TARIFF NO.: 7106.10.0000 Jamie Thomas Harimatec Inc. 1965 Evergreen Blvd. Duluth, GA 30096 RE: The tariff classification of solder powder from Japan Dear Ms. Thomas: In your letter dated February 25, 2026, you requested a tariff classification ruling. The merchandise under consideration is a fine metallic powder, identified as HMP-SAC-38-25A Solder Powder. The stated components are tin (CAS no. 7440-31-5), silver Ag powder (CAS no. 7740-22-4), and copper metal (CAS no. 7440-50-8). A representative sample was submitted with your request and was sent to the U.S. Customs and Border Protection (CBP) laboratory for analysis. CBP laboratory analysis has determined that the sample contains tin, silver, and copper. The silver content is estimated to be more than 2 percent of the sample by weight. Furthermore, the laboratory determined that more than 90 percent of the sample has a particle size smaller than 0.5mm. You suggest classification of the HMP-SAC-38-25A Solder Powder in subheading 8007.00.3200, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other articles of tin: Powders and flakes.” We disagree. Note 5 to Chapter 71 of the HTSUS states that, “... any alloy containing precious metal is to be treated as an alloy of precious metal if any one precious metal constitutes as much as 2 percent by weight, of the alloy...” Note 5(c) states “Other alloys containing 2 percent or more, by weight, of silver are to be treated as alloys of silver.” Since the solder powder contains a minimum of 2 percent silver, it will be classified as an alloy of silver. Section XV, Note 1(e) excludes precious metal alloys of Chapter 71. As such, the solder powder is precluded from classification in heading 8007, HTSUS. To determine the correct subheading within Chapter 71, we look to the Chapter’s Subheading Notes. Subheading Note 1 states that for the purposes of subheading 7106.10, the expressions “powder” and “in powder form” mean products of which 90 percent or more by weight passes through a sieve having a mesh aperture of 0.5 mm. Because CBP laboratory evaluation confirmed that more than 90 percent of the sample satisfies this sieve requirement, the product meets the legal definition of a powder.
The applicable subheading for the HMP-SAC-38-25A Solder Powder will be 7106.10.0000, HTSUS, which provides for “Silver (including silver plated with gold or platinum), unwrought or in semi-manufactured forms, or in powder form: Powders.” 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 other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties 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 either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems 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 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 Yani De Leon at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division