The tariff classification of modular concrete formwork systems from Chile

N353614 September 30, 2025 CLA-2-84:OT:RR:NC:N1:104 CATEGORY: Classification TARIFF NO.: 8480.60.0090; 9903.01.25 Pamela Brown Future Forwarding Company 6180 Buffington Rd. Atlanta, GA 30349 RE: The tariff classification of modular concrete formwork systems from Chile Dear Ms. Brown: In your letter dated September 11, 2025, you requested a tariff classification ruling. The products in question are three modular formwork systems for molding vertical concrete walls. Referred to as Meva Imperial, Superslim, and Steel Ply, these systems will be imported complete or virtually complete, and unassembled. These are mold systems into which wet concrete is poured and formed by panels that can be attached together to form a mold. The Meva Imperial formwork is a vertical concrete wall forming system. The components of the system are primarily made of steel and may or may not include cover panels of 100% plywood or a plastic composite face. Interlocking units are put together to form the walls of a building or structure and then act as a mold into which concrete is placed. The components of the system include panels of varying sizes, wall ties, taper ties, corner assemblies, railing posts, she-bolts, clamps, brackets, and hardware for lifting and access. Each importation will consist of all the components required for an individual job, except in some cases for the plywood cover panels. The Superslim formwork is a vertical concrete wall forming system. The components of the system are primarily made of steel and may or may not include cover panels. Interlocking units are bolted together to form the walls of a building or structure and then act as a mold into which concrete is placed. The components of the system include aluminum strongbacks (beams and bracing members used to add structural support) of varying sizes, soldiers, railing posts, climbing platforms, lifting hardware, clamps and brackets. Each importation will in most cases consist of all the components required for an individual job. The Steel-Ply formwork is also a vertical concrete wall forming system and consists of steel ply panels, wall ties, fillers, high density plywood, corner assemblies, wedge bolts and hardware for lifting, access, and alignment. Each importation will consist of all the components required for an individual job. The applicable subheading for each of the three formwork systems, when imported unassembled but complete with all components required for an individual job, without extra or spare parts, will be 8480.60.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Molding boxes for metal foundry; mold bases; molding patterns; molds for metal (other than ingot molds), metal carbides, glass, mineral materials, rubber or plastics: Molds for mineral materials: Other types.” The general rate of duty will be free. This classification will apply even if shipments lack the plywood panels, as tariff headings include incomplete articles if the incomplete article has the essential character of the complete article. See General Rule of Interpretation 2(a), HTSUS. Typically, formwork systems imported without their plywood panels have the essential character of molds. See, e.g., Headquarters Ruling Letter 087328, dated September 26, 1990. However, formwork that is missing other components may need to be evaluated to determine whether the absence of such components cause the system to lose its essential character as a mold. In your submission, you state that the company may also import extra or spare parts in addition to complete systems, but you do not identify such parts. Note that heading 8480, HTSUS, has no subheading for parts or accessories. Therefore, any extra or spare formwork parts will need to be separately classified, even if they are shipped together with the complete formwork system. Finally, your submission states that the imported systems may be split into several containers. Note that certain multiple entries of merchandise may be treated as a single transaction, subject to meeting the legal requirements set forth in 19 U.S.C. 1484(j) and 19 C.F.R. 141.58. 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 Chile will be subject to an additional ad valorem rate of duty of 10 percent. 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 8480.60.0090, 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 (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 Arthur Purcell at arthur.purcell@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division