The tariff classification of rub rails from Italy

N351637 July 28, 2025 CLA-2-73:OT:RR:NC:N1:164 CATEGORY: Classification TARIFF NO.: 7326.90.8688; 9903.81.90; 9903.01.25 Margherita Rezzonico Mate USA LLC 451 Goolsby Blvd. Deerfield Beach, FL 33442 RE: The tariff classification of rub rails from Italy Dear Ms. Rezzonico: In your letter dated July 2, 2025, you requested a tariff classification ruling on rub rails from Italy. Product information was submitted with your request. The items under consideration are described as rub rails to be installed over the joint between a boat’s deck and hull. You assert that the rub rails cover the joint for aesthetic purposes and protect the boat by absorbing impacts with other objects. The rub rails consist of a polyvinyl chloride (PVC) plastic base and a C-shaped grade 316 stainless steel profile with a core of PVC. During installation, the flexible PVC base follows the contour of the hull and is placed directly on the boat’s surface. Once the base is in place, the stainless steel and PVC profile is screwed or riveted into position within grooves on the base. Merchandise is classifiable under the Harmonized Tariff Schedule of the United States (HTSUS) in accordance with the General Rules of Interpretation (GRIs). GRI 1, HTSUS, states in part that for legal purposes, classification shall be determined according to the terms of the headings, any relative section or chapter notes and, unless otherwise required, according to the remaining GRIs taken in order. Goods that are, prima facie, classifiable under two or more headings, are classifiable in accordance with GRI 3. GRI 3(b) states in part that composite goods consisting of different materials or made up of different components, which cannot be classified by reference to GRI 3(a), are to be classified as if they consisted of the component which gives them their essential character. Inasmuch as no essential character can be determined, GRI 3(b) does not apply. GRI 3(c) states that, if neither GRI 3(a) nor GRI 3(b) applies, merchandise shall be classified in the heading which occurs last in numerical order among those which equally merit consideration. In this case, the rub rails are composite goods consisting of PVC and stainless steel. Based on the submitted information and manual examination of provided samples, the PVC and stainless steel are both substantial in size and functionally significant. The PVC base provides a flexible structure to attach the stainless steel and PVC profile and offers a foundation for shock absorption from impacts with other objects. Furthermore, the stainless steel and PVC profile provides a semi-rigid, corrosion resistant, and aesthetically pleasing outer surface for contact with other objects. In totality, the PVC and stainless steel materials are of equal importance to the composite good. As a result, essential character cannot be determined by GRI 3(b) and GRI 3(c) must be utilized. Here, the stainless steel component occurs last in numerical order. Accordingly, the rub rails are classified as articles of stainless steel. The applicable subheading for the rub rails will be 7326.90.8688, HTSUS, which provides for Other articles of iron or steel: Other: Other: Other: Other: Other. The general rate of duty will be 2.9 percent ad valorem. On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter 99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 percent upon the value of the steel content. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.81.90, in addition to subheading 7326.90.8688, HTSUS. Derivative iron or steel products processed in another country from steel articles melted and poured in the United States, provided for in heading 9903.81.92, are not subject to the additional ad valorem duties. 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. For products covered by subheading 9 903.81.90, this additional duty applies to the non-steel content of the merchandise. 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 7326.90.8688, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 (C.F.R.), 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 C.F.R. 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 Paul Taylor at paul.m.taylor@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division