The tariff classification of a roof patch from Indonesia

N307544 December 5, 2019 CLA-2-44:OT:RR:NC:N4:434 CATEGORY: Classification TARIFF NO.: 4421.99.9780 Mr. Ken Jiang Sinobec Resources LLC 1901 Green Road Pompano Beach, FL 33064 RE: The tariff classification of a roof patch from Indonesia Dear Mr. Jiang: In your letter, dated November 12, 2019, you requested a tariff classification ruling. Product information and photos were submitted in lieu of a sample. The item under consideration is a “Roof Patch Plug.” It consists of two complementary pieces, which installed together, are designed to patch holes in roofs. The actual patch portion is an eight-inch square of oriented strand board (OSB). Once positioned over the hole, a separate twelve-inch square metal flange is used to frame the OSB and nail it in place, securing both to the roof. Classification of merchandise under the HTSUS is in accordance with the General Rules of Interpretation (GRIs). GRI 3(b) provides that composite goods consisting of different materials or made up of different components shall be 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. The roof patch is a composite article comprised of both wood and metal. We find that the essential character is imparted by the wooden element. The wooden portion is essential to the use of the article, as it forms the actual patch. The applicable subheading for the “Roof Patch Plug” will be 4421.99.9780, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other articles of wood: Other: Other: Other: Other: Other. The rate of duty will be 3.3 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 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 Charlene Miller at charlene.s.miller@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division