The tariff classification of a zinc alloy ring from the Netherlands

N362770
July 20, 2026
CLA-2-85:OT:RR:NC:N4:410
CATEGORY: Classification
TARIFF NO.: 8509.90.5500
Robert Leo Meeks, Sheppard, Leo & Pillsbury LLP 570 Lexington Avenue, Suite 2405 New York, NY 10022 RE: The tariff classification of a zinc alloy ring from the Netherlands Dear Mr. Leo: In your letter dated June 30, 2026, you requested a tariff classification ruling on behalf of Discus Dental LLC. The merchandise under consideration is identified as a ring made of a die-cast zinc alloy. The images in your submission illustrate that the zinc alloy ring is a C-shaped, circular ring with a distinct raised flange running along the outer circumference and features cutouts/notches. You state that the zinc alloy ring is a purely mechanical metal component designed for use solely with the electric toothbrush. It is imported as a standalone mechanical component, without any electronic elements. In your submission, you suggest that the zinc alloy ring should be correctly classified in subheading 8509.90.5500, Harmonized Tariff Schedule of the United States (HTSUS), as a toothbrush part. We agree. The applicable subheading for the zinc alloy ring will be 8509.90.5500, HTSUS, which provides for “Electromechanical domestic appliances, with self-contained electric motor, other than vacuum cleaners of heading 8508; parts thereof: Parts: Other: Other: Other”. The rate of duty will be 4.2 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/. 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 Michael Chen at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division