The tariff classification of mop pad holders and a telescopic pole from China.

N319364 June 2, 2021 CLA-2-96:OT:RR:NC:N4:415 CATEGORY: Classification TARIFF NO.: 3926.90.9985; 7616.99.5190; 9603.90.8050; 9903.88.03; 9903.88.15 Ms. Donna Palermo Mid America Overseas, Inc. 11 Commerce Drive Cranford, NJ 07016 RE: The tariff classification of mop pad holders and a telescopic pole from China. Dear Ms. Palermo: In your letter dated May 11, 2021, you requested a tariff classification ruling on behalf of your client, Sysco Guest Supply, LLC. Images were provided in lieu of samples. There are four products submitted for consideration. They are all intended to be used primarily by hotels. The first item is described as an “Ecolab swivel pad holder,” item number 0011244. This product is an unassembled mop head featuring a plastic pad holder and three cleaning pads. Per your documentation, the non-abrasive cleaning pad is for cleaning tubs and shower walls, the “Power Eraser Plus” pad is designed to scrub tough-to-clean stains on tub bottoms, and the microfiber cleaning pad is for cleaning bathroom floors. The second item is described as the “Doodlebug swivel pad holder,” item number 3M100. This is a threaded plastic pad holder that works with 4.625-inch by 10-inch cleaning pads. It will be imported on its own and without any cleaning pads. As such, this mop component would be classified according to its constituent materials and not within heading 9603. The third item is described as the “Impact Floor Pad Holder Gray,” item number 0008437. This product is an unassembled mop head featuring a plastic pad holder and two cleaning pads. The first cleaning pad is a brown stripping pad and the second is a white polishing pad. The fourth item is described as the “Ecolab telescopic 50-inch pole,” item number 0023218. The pole is comprised of an aluminum extension shaft that varies in adjustable telescopic lengths from 34 inches to 51 inches, and plastic components. The acrylonitrile butadiene styrene (ABS) plastic components include a handle grip on one end of the pole and a connector component on the other end. You indicate that the subject poles help room attendants reach high walls and other difficult-to-clean areas. The pole attaches to tool heads with a specially designed quick connect fitment. The applicable subheading for the “Ecolab swivel pad holder,” item number 0011244, and the “Impact Floor Pad Holder,” item number 0008437, will be 9603.90.8050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[b]rooms, brushes (including brushes constituting parts of machines, appliances or vehicles), hand-operated mechanical floor sweepers, not motorized, mops and feather dusters; prepared knots and tufts for broom or brush making; paint pads and rollers; squeegees (other than roller squeegees): [o]ther: [o]ther: [o]ther.” The column one, general rate of duty is 2.8% ad valorem. The “Doodlebug swivel pad holder,” item number 3M100, would be considered an article of plastic, and as it is not more specifically provided for elsewhere, the applicable subheading will be 3926.90.9985, HTSUS, which provides for “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther.” The column one, general rate of duty is 5.3 percent ad valorem. The applicable subheading for the Ecolab telescopic pole, item number 0023218, will be 7616.99.5190, HTSUS, which provides for “[o]ther articles of aluminum: [o]ther: [o]ther: [o]ther: [o]ther: [o]ther: [o]ther. The column one, general rate of duty is 2.5 percent ad valorem. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under 7616.99.5190, 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., 9903.88.03, in addition to subheading 7616.99.5190, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 3926.90.9985 and 9603.90.8050, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to the respective subheading 3926.90.9985 or 9603.90.8050, 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 trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, 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 at https://hts.usitc.gov/current. The Ecolab telescopic pole may be subject to antidumping duties and countervailing duties (AD/CVD). Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and Compliance office in the International Trade Administration of the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP). You can contact them at https://trade.gov/enforcement/ (click on “Contact Us”). For your information, you can view a list of current AD/CVD cases at the United States International Trade Commission website at https://www.usitc.gov/trade_remedy/documents/orders.xls, and you can search AD/CVD deposit and liquidation messages using CBP’s AD/CVD Search tool at https://aceservices.cbp.dhs.gov/adcvdweb. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR 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 Kristopher Burton at kristopher.burton@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division