The tariff classification of an aluminum bracket and ladder stabilizers from China

N361563June 11, 2026CLA-2-83:OT:RR:NC:N5:121
CATEGORY: Classification
TARIFF NO.: 8302.50.0000; 7616.99.5190
Kari AidukMohawk Global Logistics123 Air Cargo Rd,N. Syracuse, NY 13212RE: The tariff classification of an aluminum bracket and ladder stabilizers from ChinaDear Ms. Aiduk:In your letter dated
May 15, 2026
, you requested a tariff classification ruling on behalf of Werner Co.Photographs and descriptions of the merchandise were included in your inquiry.The first article under consideration is described as a ladder jack, part number AC10-14-02. It is a triangularshaped aluminum bracket with a clamping mechanism. The adjustable bracket is mounted vertically to anextension ladder and functions to support and secure planks or platforms that are positioned between twoladders.The second article under consideration is described as a ladder stabilizer, part number AC96. It is a C-shapedaluminum stabilizer that is mounted to the upper portion of an extension ladder. It functions to secure andstabilize the ladder by distributing weight across a broader surface area and creating a stable interfacebetween the ladder and the supporting structure. The stabilizer provides a span of approximately 47 inchesand creates a standoff of approximately 10 inches from the contact surface.The third article under consideration is described as a ladder stabilizer, part number AC78. This aluminumstabilizer incorporates a spring-loaded locking mechanism that allows for quick installation and removal. It ismounted to the upper portion of an extension ladder and functions to secure and stabilize the ladder bysecuring its positioning and distributing weight relative to the supporting surface. The stabilizer provides aspan of approximately 44 inches and a standoff of approximately 10 inches.In your letter, you propose classification of the ladder jack bracket and ladder stabilizers in subheading8302.49.6085, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Base metalmountings, 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 partsthereof: Other: Other: Other: Other. We disagree. As noted in Headquarters ruling 960428, the word
“fittings” is defined as “the fixtures and fitments of a building,” and the word “fixtures” as “something fixedor fastened in position;” “articles attached to a house or land and regarded as legally part of it.” The ladderjack bracket and ladder stabilizers are removable articles; they are not fixed in place and therefore they do notmeet the terms of heading 8302. Additionally, we note that the ladder jack bracket and ladder stabilizers areused on a ladder. Ladders do not have the characteristics of and are not similar or akin to the articlesenumerated in the terms of heading 8302, namely furniture, doors, staircases, windows, blinds, coachwork,saddlery, trunks, chests, and caskets. The ladder jack bracket and ladder stabilizers, therefore, are not suitablefor these articles and cannot be classified in subheading 8302.49 HTSUS.It is our opinion that the ladder jack bracket is more specifically provided for in subheading 8302.50.0000,HTSUS, which provides for Base metal hat racks, hat-pegs, brackets and similar fixtures. The ExplanatoryNotes to the Harmonized Commodity Description and Coding System (ENs) represent the officialinterpretation of the Harmonized System at the international level. While neither legally binding nordispositive, the ENs provide a commentary on the scope of each heading of the HTSUS and are generallyindicative of the proper interpretation of these headings. EN 8302 (G) states that 8302.50, HTSUS, covershat-racks, hat-pegs, brackets, and similar fixtures “such as coat racks, towel racks, dish-towel racks,dish-cloth racks, brush racks, and key racks.” While the term “bracket” is not defined in either the HTSUS orthe Explanatory Notes, Webster’s Dictionary defines “bracket” as: “an overhanging member that projectsfrom a structure (such as a wall) and is usually designed to support a vertical load or to strengthen an angle.”Additionally, the essential characteristics of items classified in 8302.50, HTSUS, are that they made of basemetal, are affixed to a wall, and function to hang, hold, or support items. Here, the subject aluminum ladderjack bracket projects from a ladder and provides a mount that allows a plank or platform to sit vertically. It isdesigned to support and hang a vertical load: the plank or platform. Based on the foregoing, we find that thesubject ladder jack bracket is described in subheading 8302.50.0000, HTSUS.The applicable subheading for the ladder jack, part number AC10-14-02 will be 8302.50.0000, HTSUS,which provides for Hat-racks, hat pegs, brackets and similar fixtures, and parts thereof. The general rate ofduty will be free.Heading 7616, HTSUS, is a residual or basket provision which covers a wide range of aluminum articles thatare not more specifically provided for elsewhere in the HTSUS. The ENs to heading 7616 state that “Thisheading covers all articles of aluminum other than those covered by the preceding headings of this Chapter,or by Note 1 to Section XV, or articles specified or included in Chapter 82 or 83, or more specificallycovered elsewhere in the Nomenclature.” An article of aluminum can be classified in heading 7616 if it isdetermined that the item is not more specifically provided for in any other heading of the tariff. The ladderstabilizers, AC96 and AC78, are not specifically covered elsewhere in the tariff. Accordingly, they areclassifiable in heading 7616, HTSUS.The applicable subheading for the ladder stabilizers, AC96 and AC78, will be 7616.99.5190, HTSUS, whichprovides for “Other articles of aluminum: Other: Other: Other: Other: Other.” The general rate of duty will be2.5 percent ad valorem.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 CFR177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject toperiodic verification 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