The tariff classification of a Grounding Lug Assembly from China

N307336 November 22, 2019 CLA-2-85:OT:RR:NC:N2:220 CATEGORY: Classification TARIFF NO.: 8536.90.4000; 9903.88.01 Mary Akli Quick Mount PV 2700 Mitchell Drive Walnut Creek, CA 94598 RE: The tariff classification of a Grounding Lug Assembly from China Dear Ms. Akli : In your letter dated November 04, 2019, you requested a tariff classification ruling. The item under consideration is identified as the Grounding Lug Assembly, Part No. 8181, which is described as a pre-assembled electrical grounding lug. Each lug consists of a 0.9” tin-plated aluminum terminal bar comprised of a single-threaded terminal connection with a slotted stainless steel cap screw, a single mounting hole, and operates at less than 1,000 volts. In your letter, you state that the grounding lug assembly is imported with ten lugs per package where each is pre-assembled and ready for resale and installation; no additional processing is required after importation. In use, the Grounding Lug Assembly is intended to secure electrical connections in photovoltaic panel installations. The applicable subheading for the Grounding Lug Assembly, Part No. 8181, will be 8536.90.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical apparatus…for making connections to or in electrical circuits…for a voltage not exceeding 1,000V: Other apparatus: Terminals, electrical splices and electrical couplings.” The rate of duty will be free. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8536.90.4000 HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01, in addition to subheading 8536.90.4000, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the Section 301 trade remedy, you may refer to the relevant parts of the USTR and CBP websites, which are available at: https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively 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 the 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 Karl Moosbrugger at karl.moosbrugger@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division