The tariff classification of an assembly piece from China

N362164
June 30, 2026
CLA-2-76:OT:RR:NC:N1:113
CATEGORY: Classification
TARIFF NO.: 7616.99.5190
Samantha Pate Beta Bionics 11 Hughes Irvine, CA 92618 RE: The tariff classification of an assembly piece from China Dear Ms. Pate: In your letter dated June 8, 2026, you requested a tariff classification ruling. Technical information was submitted with your request. The item under consideration is an assembly piece, Product # 110001, identified as “Housing, Slim, GFF, Demo.” This item is part of a larger assembly constructed in the United States to resemble a control panel for an insulin pump. It has no electrical or mechanical function and will be used for demonstration purposes when fully assembled. The item is made of aluminum, rectangularly shaped, and is 71 millimeters in height and 42 millimeters in width. The piece is designed to fit with another piece of similar size to resemble the housing for the control panel and has an X-brace within the piece to prevent any use in a fully functioning insulin pump. Heading 7616, Harmonized Tariff Schedule of the United States (HTSUS), is a residual or basket provision which covers a wide range of aluminum articles that are not more specifically provided for elsewhere in the HTSUS. The Explanatory Notes (ENs) to heading 7616 state that “This heading 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 specifically covered elsewhere in the Nomenclature.” An article of aluminum can be classified in heading 7616, HTSUS, if it is determined that the item is not more specifically provided for in any other heading of the tariff. The assembly piece is not specifically covered elsewhere in the tariff. Accordingly, they are classifiable in heading 7616, HTSUS. The applicable subheading for the assembly piece will be 7616.99.5190, HTSUS, which provides for “Other articles of aluminum: Other: Other: Other: Other: Other.” The general rate of duty will be 2.5 percent 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 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 Matthew Gay at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division