The tariff classification of roof clips from China

N273698 March 23, 2016 CLA-2-73:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7616.99.5090 Ms. Dorothy Trombley Affiliated USA Inc. 193 West Service Road PO Box 2421 Champlain, NY 12919 RE: The tariff classification of roof clips from China Dear Ms. Trombley: In your letter dated January 26, 2016, on behalf of Drexma Industries Inc., you requested a tariff classification ruling. A sample of a roof clip kit and installation instructions for the roof clips were submitted for our review. The merchandise under consideration is identified in your letter as “The JSR13 and JSR14 Roof Clip Kits…suitable for use with HTR heating cables…The JSR13 and JSR14 roof clips are used to secure HTR heating cables to shingle and metal seam roofs and gutters.” You stated in our telephone conversation on March 8, 2016, that the roof clips in question are made of aluminum. Each roof clip is a single piece of aluminum that features a flat back with holes for nails or screws, and a clamp on one end. The installation instructions indicate that pliers should be used to close the clamp on a heating cable. Each roof clip measures approximately 2.5 inches in length by 1.5 inches in width. The flat portion of the clip securely attaches to shingle and metal seam roofs and gutters. Nails or screws and adhesives will be used to attach the clips to the roof. The JSR13 Roof Clip Kit consists of 10 roof clips packaged in a plastic bag and the JSR14 Roof Clip Kit consists of 50 roof clips packaged in a box. The applicable subheading for the JSR13 and JSR14 Roof Clip Kits will be 7616.99.5090, Harmonized Tariff Schedule of the United States HTSUS), which provides for other articles of aluminum, other, other…other. The rate of duty will be 2.5 percent ad valorem. 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 on World Wide Web at http://www.usitc.gov/tata/hts/. This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Ann Taub at ann.taub@cbp.dhs.gov. Sincerely, Deborah C. Marinucci Acting Director National Commodity Specialist Division