The tariff classification of rope management equipment from China

N353464 September 12, 2025 CLA-2-73:OT:RR:NC:N1:164 CATEGORY: Classification TARIFF NO.: 7326.90.8688; 7616.99.5190; 4421.99.9880; 9903.01.24; 9903.85.07; 9903.81.90; 9903.01.25; 9903.88.03 Amaury de Nantes W-Link International Limited 16B, Yam Tze Commercial Building Hong Kong 999077 China RE: The tariff classification of rope management equipment from China Dear Amaury de Nantes: In your letter dated September 8, 2025, you requested a tariff classification ruling regarding rope management equipment from China. You submitted product information with the request. The first item under consideration is the “Hands Up” rigging product which enables arborists to connect and manage working ropes during tree rigging operations. It is a curved piece of metal with a central loop that allows ropes of various diameters to be guided, redirected, or temporarily secured without knots. The submitted product literature indicates the Hands Up can also be used to attach carabiners through its loop. The Hands Up is constructed of corrosion resistant stainless steel and is available in small, medium, and large sizes. In addition, you confirm it is used entirely by hand and is not powered or mechanical. The “Hexaring” is described as a closed, circular ring which provides a fixed attachment or redirection point for textile ropes during tree rigging and lowering operations. During use, a rope is looped around the ring’s exterior channel and another rope is passed perpendicularly through the internal opening. You assert that the Hexaring’s design reduces friction by guiding the ropes and distributing load forces. The Hexaring consists of aluminum alloy with a hard anodized coating for durability and corrosion resistance. The Hexaring is available in medium, large, and extra-large sizes and is designed to accommodate ropes of varying diameters. You state it is manually operated, not mechanical, and requires no power source. The “Hexarig” is a fixed bollard system which provides arborists attachment points for lowering loads and rigging ropes up to 20 millimeters in diameter. The product lets a user control the descent of branches and other loads by adjusting the amount of friction between the rope and bollard. Specifically, the user can change the number of rope wraps around the bollard to increase or decrease friction. By manipulating the rope wraps, and thus friction, the user can control the descent of the rope. In addition to the central bollard, the product features other rope attachment points and slots for ratchet straps. The Hexarig primarily consists of aluminum alloy but also contains steel and polyester components. You confirm the Hexarig is manually operated, not mechanical, and requires no power source. The “Hexapush” is described as an ergonomic handheld item to advance friction hitches along climbing ropes. The product consists of two semicircular pieces of anodized aluminum which are placed around a rope and fastened together with metal pins to make a single domed ring. When the pieces are separated, a bungee cord keeps them attached. There is also a wooden version which is constructed of laminated layers of wood. During use, a climber grasps the Hexapush to move an adjacent friction hitch as desired without having to directly grasp the hitch itself. You state that the ergonomics of the product can improve a user’s grip while reducing rope burn and hand fatigue. Additionally, you state the Hexapush products are manually operated, not mechanical, and require no power source. The applicable subheading for the Hands Up 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: Other: Other. The general rate of duty will be 2.9 percent ad valorem. The applicable subheading for the Hexaring, Hexarig, and aluminum Hexapush will be 7616.99.5190, HTSUS, which provides for Other articles of aluminum: Other: Other: Other: Other: Other: Other. The general rate of duty will be 2.5 percent ad valorem. The applicable subheading for the wooden Hexapush will be 4421.99.9880, HTSUS, which provides for Other articles of wood: Other: Other: Other: Other: Other. The general rate of duty will be 3.3 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 subheadings 7326.90.8688, 7616.99.5190, and 4421.99.9880, HTSUS, listed above. On March 12, 2025, Presidential proclamation 10895 imposed additional tariffs on certain derivative aluminum products. Additional duties for derivative aluminum products of 50 percent are reflected in Chapter 99, headings 9903.85.04, 9903.85.07, and 9903.85.08. Products provided by heading 9903.85.08, as well as products of Chapter 76 provided by 9903.85.04 and 9903.85.07, will be subject to a duty of 50 percent upon the value of the aluminum content. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.85.07, in addition to subheading 7616.99.5190, HTSUS. Derivative aluminum articles processed in another country from aluminum articles that were smelted and cast in the United States, provided for in heading 9903.85.09, are not subject to the additional ad valorem duties. 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 of China, Hong Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. For products covered by heading 9903.81.90 or 9903.85.07, this additional duty applies to the non-steel or non-aluminum 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 subheadings 7326.90.8688, 7616.99.5190, and 4421.99.9880, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 7326.90.8688, 7616.99.5190, and 4421.99.9880, 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 7326.90.8688, 7616.99.5190, and 4421.99.9880, 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/programs-administration/trade-remedies, respectively. 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) Denise Faingar Acting Director National Commodity Specialist Division