The tariff classification of a 5-ply clad metal disc from South Korea

N361696June 1, 2026CLA-2-73:OT:RR:NC:N1:113
CATEGORY: Classification
TARIFF NO.: 7326.90.8688
Ashley ArnoldMallory Alexander International Logistics4294 Swinnea Rd.Memphis, TN 38118RE: The tariff classification of a 5-ply clad metal disc from South KoreaDear Ms. Arnold:In your letter dated
May 21, 2026
, you requested a tariff classification ruling. Technical information wassubmitted with your request.The product under consideration is a 5-ply clad metal disc, Part # 10-14908E-36. The disc is 300 millimeterseter 3 mm composed of five different alloy layers.The two outer layers are(mm) in diam, thick, and ismetal made of stainless steel alloys and make up 55% of the total weight. The three inner core layers are made ofaluminum alloys and make up 45% of the total weight. After importation the disc will be used as a blank tomanufacture cookware. In your request, you suggested the discs could be classified in subheading 7323.93.00, Harmonized TariffSchedule of the United States (HTSUS), which provides for “table, kitchen or other household articles andparts thereof, of iron or steel; iron or steel wool; pot scourers and scouring or polishing pads, gloves and thelike, of iron or steel: other: of stainless steel…” We disagree. The disc is not similar to the exemplars listed inthe Explanatory Notes (ENs) to heading 7323, HTSUS, and is not designed or intended explicitly for table orkitchen use. Thus, classification in 7323.93.00, HTSUS, is precluded.We note that the d composed of more than one metal. Section XV, Note 7 of the HTSUS, statesisc is basethat the classification of articles of base metal containing two or more base metals are to be treated as“articles of the base metal that predominates by weight over each of the other metals Based on the.”information provided, the predominating metal in the is s.discteelHeading 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 ENS to heading 7326, HTSUS, statethat “This heading covers all iron or steel articles obtained by forging or punching, by cutting or stamping orby other processes such as folding, assembling, welding, turning, milling or perforating other than articles
included in the preceding headings of this Chapter or covered by Note 1 to Section XV or included inChapter 82 or 83 or more specifically covered elsewhere in the Nomenclature.” An article of iron or steel canbe classified in heading 7326, HTSUS, if it is determined that the item is not more specifically provided forin any other heading of the tariff. The metal disc is not specifically covered elsewhere in the tariff.Accordingly, they are classifiable in heading 7326, HTSUS.The applicable subheading for the 5-ply clad metal disc will be 7326.90.8688, HTSUS, which provides for“Other articles of iron or steel: Other: Other: Other: Other: Other.” The general rate of duty will be 2.9percent ad valorem.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 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 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 Matthew Gay at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division