The tariff classification of connection claws and ballast trays for the support system for solar panels from India

N274790 April 26, 2016 CLA-2-73:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7326.90.8588 Mr. Karl F. Krueger Radix Group International d/b/a DHL Global Forwarding 2660 20th Street Port Huron, MI 48060 RE: The tariff classification of connection claws and ballast trays for the support system for solar panels from India Dear Mr. Krueger: In your letter dated March 24, 2016, on behalf of PanelClaw Inc., you requested a tariff classification ruling. Pictures, specification drawings, descriptive literature and samples for the connection claws and ballast trays were submitted for our review and will be returned as you requested. The articles under consideration are described as components of a support system for solar panels used in the construction of solar arrays. There are two item numbers for the connection claws depending on the length. The short claw is identified as item number 200049301 and the long claw is 200049302. The submitted claw is a sheet of steel that measures approximately 39 inches in length that has been stamped into a profile shape and perforated. The item is galvanized after forming and stamping. You stated in your letter that “In a solar panel array each row of solar panels is attached to the one behind by means of a claw.” The claws are bolted to the brackets that hold the panels in place. There are three item numbers for the ballast trays depending on the length. The ballast trays are identified as item numbers 200059901, 200059902 and 200059903. The submitted ballast tray is a sheet of steel that measures approximately 50 inches in length that has been stamped into a profile shape and perforated. The item is galvanized after forming and stamping. You stated in your letter that “The tray is designed to form a channel into which weights are placed in order to keep the solar panels from blowing off the roof.” The trays are bolted to the brackets that hold the panels in place. The applicable subheading for the connection claws (item numbers 200049301 and 200049302) and the ballast trays (item numbers 200059901, 200059902 and 200059903) will be 7326.90.8588, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel, other, other, other, other, other. The rate of duty will be 2.9 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 https://hts.usitc.gov/current. 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