The tariff classification of mounting hardware from China

N295238 March 28, 2018 CLA-2-83:OT:RR:NC:N1:121 CATEGORY: Classification TARIFF NO.: 8302.41.6080 Mr. Gregory Wiener Quickscrews International Corp. 5830 Las Positas Road Livermore, CA 94551 RE: The tariff classification of mounting hardware from China Dear Mr. Wiener: In your letter dated March 15, 2018 you requested a tariff classification ruling. Pictures and a part number of the product were submitted with your request. According to the information you submitted, the item under consideration is the Rooftop Flashing Kit, part number 17717, and described in the documentation you submitted as “Flashed L-Foot and U-Foot.” You state the kit is designed for the installation of solar panels and consists of three parts: a galvanized steel flashing with a U-shaped stamped indentation, an aluminum L-Foot bracket, and a 5/16" stainless steel screw. When in use, the L-Foot bracket is secured to a rooftop under the asphalt shingles with the stainless steel screw. The galvanized steel flashing is placed over the L-Foot bracket and covered by the rooftop shingles. The Explanatory Notes to the Harmonized Tariff System provide guidance in the interpretation of the Harmonized Commodity Description and Coding System at the international level. Explanatory Note X to GRI 3(b) provides that the term "goods put up in sets for retail sale" means goods that: (a) consist of at least two 2 different articles which are, prima facie, classifiable in different headings; (b) consist of articles put up together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without repacking. Goods classifiable under GRI 3(b) are classified as if they consisted of the material or component which gives them their essential character, which may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the article. This office considers the subject Rooftop Flashing Kit to be a set for tariff classification purposes. The essential character of each set is imparted by the L-Foot bracket. The applicable subheading for the Rooftop Flashing Kit will be 8302.41.6080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds coachwork…. suitable for buildings; Other; Of iron or steel, of aluminum or of zinc; Other. The rate of duty will be 3.9 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 Jennifer Jameson at jennifer.d.jameson@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division