RE: The tariff classification of aluminum component prototype from China

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364258 August 25, 2026 CLA-2-76:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7616.99.5190; 9817.85.01 Burt Shulman Innovations Unlimited LLC 116 Lifetime Ct. Ormond Beach, FL 32174 RE: The tariff classification of aluminum component prototype from China Dear Mr. Shulman: In your letter dated August 12, 2026, you requested a tariff classification ruling. Informational material was submitted with your request. The item under consideration is an inlet funnel. The funnel is designed to facilitate the retraction and storage of a hose within a machine. It is composed of an aluminum alloy, weighs 3 ounces, is 1.538 inches in height, and 5 inches in diameter. The item is a modified version of the inlet funnel described in New York Ruling N348395, dated May 2, 2025. In correspondence, you confirmed only one model will be imported, and it will be used to test its ability to provide a smooth entry path for the tubing as it retracts or is dispensed. The applicable subheading for the aluminum component will be 7616.99.5190, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other articles of aluminum: Other: Other: Other: Other: Other: Other.” The general rate of duty will be 2.5 percent ad valorem. You also inquired if the imported funnel qualifies for duty free treatment as a prototype. Per subheading 9817.85.01, HTSUS, prototype articles are “exclusively for development, testing, product evaluation, or quality control purposes.” In your letter, you stated one model of this product will be imported alone, and it will be used to test its ability to provide a smooth entry path for a retractable tube stored in a machine. Accordingly, this office finds that the aluminum inlet funnel qualifies for duty free treatment as a prototype under subheading 9817.85.01, HTSUS, which provides for “Prototypes to be used exclusively for development, testing, product evaluation, or quality control purposes.” 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