The tariff classification of Hawse Fairleads and Fairlead Mounts from China

N320731 August 12, 2021 CLA-2-76: OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7616.99.5190: 7326.90.8688: 9903.88.03 Mr. Zachary Hill Central Purchasing LLC 26677 Agoura Road Calabasas, California 91302 RE: The tariff classification of Hawse Fairleads and Fairlead Mounts from China Dear Mr. Hill: In your letter dated July 29, 2021, you requested a tariff classification ruling. Descriptions, drawings and photographs of the subject fairleads and mounts were submitted for our review. The articles under consideration are identified as Hawse Fairleads, SKU numbers 57371 and 57416, and Fairlead Mounts, SKU number 58019. The Hawse Fairleads are described in your letter as “simple, straightforward guides for the rope to the winch drum. They protect and reduce wear on the rope and help protect the winch. The Hawse Fairleads are constructed of aluminum with a powder finish coat and stainless steel mounting hardware. The Hawse Fairlead has a tapered variable radius opening that puts less stress on the tow line, minimizing wear and tear on the rope during angled winch pulls.” The subject fairleads are designed for use with synthetic winch rope. They can attach to the winch or to a mount. The Hawse Fairlead SKU number 57371 features a 6 inch mounting pattern and fits winches up to 5500 pounds. The fairlead measures 8.05 inches in length x 0.85 inches in width x 2.5 inches in height, and weighs 1.5 pounds. The Hawse Fairlead SKU number 57416 features a 4.8 inch mounting pattern and fits winches up to 5500 pounds. The fairlead measures 6.5 inches in length x 0.85 inches in width x 2.5 inches in height, and weighs 0.56 pounds. The Fairlead Mount is described in your letter as “a universal fit, designed for mounting all truck winches with a 10 inch fairlead and a 10 inch x 4.5 inch mounting pattern. It is constructed of carbon steel with a powder finish coat.” You indicated that the mount is designed to attach the fairlead to the winch and does not attach directly to the vehicle or the vehicle frame. The mount measures 13 inches in length x 7.36 inches in width x 4.25 inches in height, and weighs 4 pounds. The applicable subheading for the Hawse Fairleads, SKU numbers 57371 and 57416, will be 7616.99.5190, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of aluminum, other…other. The rate of duty will be 2.5 percent ad valorem. The applicable subheading for the Fairlead Mounts, SKU number 58019, will be 7326.90.8688, 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. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 7616.99.5190 and 7326.90.8688, 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 subheadings 7616.99.5190 and 7326.90.8688, 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, 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. 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