The tariff classification of a protective cover for an IBC container from China

N348880 May 20, 2025 CLA-2-63:OT:RR:NC:N3:351 CATEGORY: Classification TARIFF NO.: 6307.90.9891; 9903.01.24; 9903.01.25; 9903.88.15 Mr. Nathan Cannon IBC Quick Covers 3783 Stan Cannon Road Cottesloe, Perenjori 6620 Australia RE: The tariff classification of a protective cover for an IBC container from China Dear Mr. Cannon: In your letter dated May 12, 2025, you requested a tariff classification ruling. In lieu of a sample, photographs of the item were provided with your request. The item, described as a “IBC quick cover,” is a textile cover designed to fit over an intermediate bulk container (IBC) and intended to protect the container. The cover is composed of a 100 percent polyester dyed (black) woven fabric coated on one side with a polyvinyl chloride (PVC) coating. The two-panel, rectangular shaped cover with open bottom, measures 48 ½ inches in length by 40 ½ inches in width by 7 inches in height and is hemmed. The cover features the “IBC” logo sewn on the front of the cover and four aluminum grommets on each side. Each grommet is spaced 10 ½ inches apart on the shorter sides and 13 ¼ inches on the longer sides. A ¼ inch in diameter bungee cord constructed of a latex rubber core sheathed with 100 percent polyester braided yarns is threaded through the 16 grommets and knotted at one corner. Two plastic hooks are attached to the cord on each side and are used for fastening the cover to the IBC container. The applicable subheading for the cover will be 6307.90.9891, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other made up articles, including dress patterns: Other: Other: Other: Other: Other.” The rate of duty will be 7 percent ad valorem. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition to subheading 6307.90.9891, HTSUS, listed above. Effective April 5, 2025, Executive Orders implemented ?Reciprocal Tariffs. ?All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries will be subject to an additional 10 percent ad valorem rate of duty. ?At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading 6307.90.9891, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 6307.90.9891, 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 subheading 6307.90.9891, HTSUS, listed above. The HTSUSA 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/. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. ?This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). ?This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. ?In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. ? Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Kristine Dodge at kristine.dodge@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division