The tariff classification of steel bases for solar panels from India

N310163 March 18, 2020 CLA-2-73:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7326.90.8688 Mr. Arjun Singh Quest Global 378 Maple Grove Drive Oakville, Ontario L6J 4V5 Canada RE: The tariff classification of steel bases for solar panels from India Dear Mr. Singh: In your letter dated February 26, 2020, you requested a tariff classification ruling on steel bases. Photographs, drawings, installation and usage instructions, the base manufacturing process and steel specifications were provided for our review. In your letter you identified the product as Panel Claw’s commercial flat roof base. The steel base is a finished component of a support system used to support solar panels in solar arrays, specifically for installation of Panel Claw’s mounting system for flat roofs. The base acts as the point of contact between the flat roof and the system, and is the load bearing component. You stated that “The base is used to connect columns of other support members. The base component is made from ASTM A1008 Grade 80 Structural Steel cold rolled sheet which is fabricated to a specified shape through the cold forming folding fabrication process. The component has multiple slots and holes and comes in three different lengths.” You indicated that the base is a finished product and requires no additional processing. The raw sheet steel is coated with a zinc-aluminum-magnesium alloy coating for corrosion protection. The subject base measures approximately 1.9 inches in height x 1.2 inches in width x 16 inches in length. The applicable subheading for steel bases for solar panels will be 7326.90.8688, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel, 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 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 Ann Taub at ann.taub@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division