The eligibility under the United States-Mexico-Canada Agreement (USMCA) of copper and brass kitchen and bathroom sinks from Mexico

N363345August 11, 2026OT:RR:NC:N4:N4:422
CATEGORY: Classification, Trade Programs
TARIFF NO.: 7418.20.1000; 7418.20.5000
Victor SaucedoMonte GrandeCalle Candilejas 3Salvador Escalante 61800MexicoRE: The eligibility under the United States-Mexico-Canada Agreement (USMCA) of copper and brasskitchen and bathroom sinks from MexicoDear Mr. Saucedo:In your letter dated
July 15, 2026
, you requested a binding ruling on the tariff classification and eligibility ofkitchen and bathroom sinks under the United States-Mexico-Canada Agreement (USMCA). Photographswere submitted along with your request.The subject merchandise are copper and brass kitchen and bathroom sinks. The finished sinks are intendedfor residential or commercial kitchen use and residential bathroom use. The copper and brass sinks areimported as finished articles ready to be installed into or onto kitchen countertops, bathroom vanities,cabinets, or other supporting surfaces.Item 1 is a copper kitchen sink. The rectangular-shaped sink is made of 100% copper. The item measuresapproximately 33 inches long by 22 inches wide by 9 inches deep. The copper sink contains a drain openingof approximately 3.50 inches in diameter.Item 2 is a copper kitchen sink. The rectangular-shaped sink is made of 100% copper. The item measuresapproximately 33 inches long by 22 inches wide by 9 inches deep. The copper sink contains a drain openingof approximately 3.50 inches in diameter.Item 3 is a copper bathroom sink. The circular-shaped sink is made of 100% copper. The item measuresapproximately 16 inches long by 12 inches wide by 4.50 inches deep. The copper sink contains a drainopening of approximately 1.80 inches in diameter.
Item 4 is a brass kitchen sink. The rectangular-shaped sink is made of 100% brass. The item measuresapproximately 33 inches long by 22 inches wide by 9 inches deep. The brass sink contains a drain opening ofapproximately 3.50 inches in diameter.Item 5 is a brass bathroom sink. The circular-shaped sink is made of 100% brass. The item measuresapproximately 16 inches long by 12 inches wide by 4.50 inches deep. The brass sink contains a drain openingof approximately 1.50 inches in diameter.Classification:The applicable subheading for Item 1, the copper kitchen sink, Item 2, the copper kitchen sink, and Item 3,the copper bathroom sink will be 7418.20.5000, Harmonized Tariff Schedule of the United States (HTSUS),which provides for “Table, kitchen or other household articles and parts thereof, of copper; pot scourers andscouring or polishing pads, gloves and the like, of copper; sanitary ware and parts thereof, of copper: Sanitaryware and parts thereof: Other.” The general rate of duty will be 3 percent ad valorem.The applicable subheading for Item 4, the brass kitchen sink and Item 5, the brass bathroom sink will be7418.20.1000, HTSUS, which provides for “Table, kitchen or other household articles and parts thereof, ofcopper; pot scourers and scouring or polishing pads, gloves and the like, of copper; sanitary ware and partsthereof, of copper: Sanitary ware and parts thereof: Of copper-zinc base alloys (brass).” The general rate ofduty will be 3 percent ad valorem.Facts:The raw materials and components are sourced as follows:100% copper sheet: Mexico100% brass sheet: MexicoAll the manufacturing processes performed in Mexico are as follows:The copper or brass sheet is traced and cut to the required dimensions.The copper or the brass is manually hammered and formed.The formed copper or brass components are assembled and permanently joined by welding.Once the body of the sink has been completed, a drain opening is made in the center of the sink.The finished sink is patinated using heat and fire to obtain the desired surface appearance.The sink is cleaned, inspected, detailed, packed, and exported to the United States.USMCA:The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30,2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of theUSMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note (“GN”)11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good isan originating good for purposes of the USMCA. GN 11(b) states:For the purposes of this note, a good imported into the customs territory of the United States from theterritory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tarifftreatment provided for in the applicable subheading and quantitative limitations set forth in the tariff scheduleas a “good originating in the territory of a USMCA country” only if-(i) the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries;
(ii) the good is a good produced entirely in the territory of one or more USMCA countries, exclusively fromoriginating materials; (iii) the good is a good produced entirely in the territory of one or more USMCA countries usingnon-originating materials, if the good satisfies all applicable requirements set forth in this note (including theprovisions of subdivision (o));The copper and brass kitchen and bathroom sinks qualify for USMCA upon compliance with all applicablelaws, regulations, and agreements.Based on the facts provided, the copper and brass kitchen and bathroom sinks qualify for USMCApreferential treatment, because they are considered a good wholly obtained or produced entirely in a USMCAcountry under General Note 11(b) (i). The goods will, therefore, be entitled to a free rate of duty under theUSMCA upon compliance with all applicable laws, regulations, and agreements.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 Dana L. Salas at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division