The tariff classification of steel drainage building materials from Ukraine

N361119May 27, 2026CLA-2-73:OT:RR:NC:N5:121
CATEGORY: Classification
TARIFF NO.: 7326.90.8688; 7324.90.0000
Andrii IefimenkoVodaland USA LLC3120 Riverport Tech Center DrMaryland Heights, MO 63043RE: The tariff classification of steel drainage building materials from UkraineDear Mr. Iefimenko:In your letter dated
April 29, 2026
, you requested a tariff classification ruling for various steel products usedfor indoor or outdoor drainage purposes. Photographs and descriptions of the merchandise were included inyour inquiry.The first item under consideration is described as a stainless-steel grating, item number 205018. It is aheelproof channel grate that measures 39.5 inches long, 5.8 inches wide, and 1 inch high. It is designed todrain water and keep walkways safe and accessible. It is commonly used in patios, sidewalks, andcommercial pedestrian zones and plazas.The second item under consideration is described as a pre-sloped stainless-steel linear drain channel, partnumbers 992201 through 992215. It measures 39.375 inches long, 6.25 inches wide and weighs 20.15pounds. This channel is a pre-sloped 4-inch trench that is designed to capture and direct water toward thedrain. It is commonly used in kitchens, wineries, breweries, and sanitary locations.The third item under consideration is described as a stainless-steel drain channel mini-slot, item number994000. The slot measures 5/8 inches wide and the entire channel measures 39.25 inches long, 2.375 incheswide, and weighs 7.6 pounds. These drain channels are designed to capture and direct water toward the drainin areas such as patios, pool decks, and outdoor living areas.The fourth item under consideration is described as a stainless-steel, pre-sloped, inline drainage basin, itemnumber 992393-8. It includes a mesh grate, debris basket, a foul air trap, and a 4-inch vertical outlet toconnect to the water system. It measures 11.875 inches long, 11.875 inches wide, 13.625 inches high, andweighs 49 pounds. The drainage basin is designed to manage water in commercial and industrialenvironments.
The fifth item under consideration is described as galvanized steel 4-inch channel installation mountingbrackets, item numbers 6104, 6124, 6154, 6174, and 6194. The brackets are used to level and stabilize a4-inch plastic channel drain system as it is being set in concrete.In your submission, you proposed classification for the grating (item 1) under subheading 7321.89,Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Stoves, ranges, grates,cookers (including those with subsidiary boilers for central heating), barbecues, braziers, gas rings, platewarmers and similar nonelectric domestic appliances, and parts thereof, of iron or steel: Other Appliances:Other, including appliances for solid fuel.” We disagree. The grating does not fall within the scope ofheading 7321, and therefore, subheading 7321.89 is not applicable.You proposed classification for the liner drain channels and the drain channel mini-slots (items 2 and 3)under subheading 7324.90.0000, HTSUS, which provides for Sanitary ware and parts thereof, of iron or steel:Other, including parts. We disagree. The linear drain channels and the drain channel mini-slots are merelychannels that collect water. While they direct the flow of the water, they do not connect directly to the watersystem and are therefore not considered sanitary ware for tariff purposes. See HQ (2021) and HQ H306046 (2019)H251048 .Additionally, you proposed classification for the mounting brackets (item 5) under subheading 8302.49.60,HTSUS, which provides for Base metal mountings, fittings and similar articles suitable for furniture, doors,staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like…: Other mountings,fittings and similar articles, and parts thereof: Other: Other: Of iron or steel, of aluminum or of zinc. Wedisagree. These mounting brackets support trench drains. Trench drains do not have the characteristics of andare not similar or akin to the articles enumerated in the terms of heading 8302, namely furniture, doors,staircases, windows, blinds, coachwork, saddlery, trunks, chests, and caskets. The mounting brackets are notused with any of the exemplars of heading 8302, and therefore cannot be classified in heading 8302, HTSUS.Heading 7326, HTSUS, is a residual or basket provision which covers a wide range of iron or steel articlesthat are not more specifically provided for elsewhere in the HTSUS. The Explanatory Notes (ENs) to heading7326 state that “This heading covers all iron or steel articles obtained by forging or punching, by cutting orstamping or by other processes such as folding, assembling, welding, turning, milling or perforating otherthan articles included in the preceding headings of this Chapter or covered by Note 1 to Section XV orincluded in Chapter 82 or 83 or more specifically covered elsewhere in the Nomenclature.” An article of ironor steel can be classified in heading 7326 if it is determined that the item is not more specifically provided forin any other heading of the tariff. The grating, drain channels (), and mountingPre-Slope and Mini-Slotbrackets are not specifically covered elsewhere in the tariff. Accordingly, they are classifiable in heading7326, HTSUS.The applicable for the gratingfor subheading - item number 205018, the pre-sloped stainless-steel lineardrain channel - part numbers 992201 through 992215, the stainless-steel drain channel mini-slot - itemmounting bracketnumber 994000, and the s - item numbers 6104, 6124, 6154, 6174, and 6194 (items 1, 2, 3,will be 326.90.8688, HTSUS, which provides for Other articles of iron or steel: Other: Other: Other:and 5) 7Other: Other.The general rate of duty will be 2.9 percent ad valorem. The applicable subheading for the stainless-steel pre-sloped inline drainage basin, item number 992393-8(item 4) will be 7324.90.0000, HTSUS, which provides for Sanitary ware and parts thereof, of iron or steel:Other, including parts. 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 convenienceand are subject to change. The text of the most recent HTSUS and the accompanying duty rates are providedat 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 theclassification 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 athttps://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page athttps://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 Jennifer Jameson at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division