The tariff classification of a metal label from China

N300405 September 21, 2018 CLA-2-83:OT:RR:NC:N1:121 CATEGORY: Classification TARIFF NO.: 8310.00.0000 Tahir Ahmed Supremia International 2 Princess Road, Suite 2C Lawrenceville, NJ 08648 RE: The tariff classification of a metal label from China Dear Mr. Ahmed: In your letter dated September 4, 2018 you requested a tariff classification ruling. The submitted sample was examined and will be returned per your request. The product under consideration is a metal and wood label to be used on bottles of Basil Hayden Kentucky Bourbon Whiskey. The label consists of a wood veneer strip approximately 1 inch wide and 9 ½ inches long with adhesive on the back and a paper liner covering the adhesive. On the face of the wood veneer there is a bronze strip approximately ¼ inch wide and 5 inches long secured with a rivet at each end. Embossed on the bronze strip is the brand name “Basil Hayden”. Additionally, centered on top of the bronze strip are the letters “B” and “H”. The letters are made of aluminum, are approximately ¾ inch wide by ¾ inch high, and are riveted through the bronze strip and wood veneer. When the paper liner is removed exposing the adhesive, the flexibility of the thin wood veneer strip allows the label to be applied around the circumference of a bottle adding a highly decorative product branding. The applicable subheading for the metal and wood Basil Hayden brand label will be 8310.00.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Sign plates, name plates, address plates and similar plates, numbers, letters and other symbols, and parts thereof, of base metal, excluding those of heading 9405. The rate of duty will be free. Effective July 6, 2018, the Office of the United States Trade Representative (USTR) imposed an additional tariff on certain products of China classified in the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(b), HTSUS. The USTR imposed additional tariffs, effective August 23, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(d), HTSUS. Subsequently, the USTR imposed further tariffs, effective September 24, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(f) and U.S. Note 20(g), HTSUS. For additional information, please see the relevant Federal Register notices dated June 20, 2018 (83 F.R. 28710), August 16, 2018 (83 F.R. 40823), and September 21, 2018 (83 F.R. 47974). Products of China that are provided for in subheading 9903.88.01, 9903.88.02, 9903.88.03, or 9903.88.04 and classified in one of the subheadings enumerated in U.S. Note 20(b), U.S. Note 20(d), U.S. Note 20(f) or U.S. Note 20(g) to subchapter III shall continue to be subject to antidumping, countervailing, or other duties, fees and charges that apply to such products, as well as to those imposed by the aforementioned Chapter 99 subheadings. Products of China classified under subheading 8310.00.0000, HTSUS, unless specifically excluded, are subject to the additional 10 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8310.00.0000, HTSUS, listed above. The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading. 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