The tariff classification and country-of-origin of a polyvinyl chloride (PVC) single-hung window system

N362904
July 15, 2026
CLA-2-39:OT:RR:NC:N5:137
CATEGORY: Classification
TARIFF NO.: 3925.20.0020
Richard Gross A. Renovations International LLC 5890 Castle Run San Antonio, TX 78218 RE: The tariff classification and country-of-origin of a polyvinyl chloride (PVC) single-hung window system Dear Mr. Gross: In your letter dated July 7, 2026, you requested a tariff classification ruling. Product SKU: IGZ-82-SH-3672-EGR, 82 Series Single-Hung Window System, egress configuration, is a vertically sliding, single-hung window. It is comprised of a frame extruded from unplasticized PVC and reinforced with steel segments, and incorporating a 19 mm insulated glass unit (IGU). It will be imported with all the required hardware and weather seals. The applicable subheading for the PVC single-hung window system will be 3925.20.0020, Harmonized Tariff Schedule of the United States (HTSUS), which provides for builders’ ware of plastics, not elsewhere specified or included: doors, windows and their frames and thresholds for doors: windows and window frames. The general rate of duty will be 5.3 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/. You also requested a country-of-origin determination for this product. All raw materials to include PVC, glass panes, ethylene-propylene-diene (EPDM) rubber, and steel are sourced from China. All of the following manufacturing steps take place in China: Raw PVC compound is melted and extruded into 82 series multi-chamber profiles. PVC profiles are cut to length for specific window dimensions.

Pre-cut galvanized steel liner segments are inserted into designated chambers in the PVC profiles and secured using self-tapping screws. PVC profile corners are heat-welded to from the structural frame and sash assemblies. Insulated glass Unit (IGU), balance mechanism and locks are installed. The sash is mounted into the frame. Finished units are packaged and labeled for shipment. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). All the component materials originate in China and all the manufacturing steps for the window system take place in China. Therefore, the country-of-origin of the 82 Series Single-Hung Window system is China. 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 Christina Allen at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division