The tariff classification of plastic caps and plugs from China.

N355034 November 5, 2025 CLA-2-39:OT:RR:NC:N4:415 CATEGORY: Classification TARIFF NO.: 3926.90.9989; 9903.01.24; 9903.01.25; 9903.88.15 James Trubits Mohawk Global Logistics 4455 Genesee Street, Suite 521 Buffalo, NY 14086 RE: The tariff classification of plastic caps and plugs from China. Dear Mr. Trubits: In your letter dated October 20, 2025, you requested a tariff classification ruling on behalf of your client, Caplugs, Inc. Images were provided in lieu of samples. There are five products under consideration. They are all intended for different applications such as serving as a temporary masking cap / plug during powder coating or painting processes. The industrial procedure and temperatures used will determine if they can be reused. Your submission indicates nothing will be attached to these masking articles. The first is described as the TS-19 silicone tapered cap and plug. It is used in masking applications that require temperature and corrosion resistance. This vented article can function either as a cap or a plug. The second is described as the SWP Series silicone washer plug (SWP-200-312-230) and is designed for masking around a hole for grounding purposes or can be used as a dual plug. The third is described as the SC-SH Ultrabake™ silicone cap (SC1062-1500) and is designed to mask plain and threaded studs, tube ends, and slotted holes. It is recommended for powder coating, e-coating, plating, and anodizing. This article can function either as a cap or a plug. The fourth is described as the silicone flangeless masking plug (UFP00625). It is recommended as a masking plug for powder coating, e-coating, plating, and anodizing applications. The plug is pushed into a threaded or non-threaded hole and is intended to protect threaded holes without masking the surrounding area. The fifth is described as the TSV Series Caplug (TSV-1). It is intended to be used as a tapered cap or plug during powder coating and curing when back-pressure could be an issue. We note that after the issuance of Jing Mei Automotive (USA) v. United States, 682 F. Supp. 3d 1354 (Ct. Int’l Trade 2023), “stoppers, lids, caps and other closures” of heading 3923 must be closures for use with some type of container or similar article used for packing, supporting, or conveyance of goods only. Thus, these articles would be classified elsewhere. As these caps and plugs would be considered articles of plastic, and as they are not more specifically provided for elsewhere, the applicable subheading will be 3926.90.9989, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther.” The column one, general rate of duty is 5.3 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 for by subheading 9903.01.24, HTSUS, other than products classifiable under subheadings 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 subheading, i.e., 9903.01.24, in addition to subheading 3926.90.9989, 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 of China, Hong Kong, and Macau 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, 9903.01.25, in addition to subheading 3926.90.9989, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 3926.90.9989, 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 3926.90.9989, 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/remedies/301-certain-products-china, 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 (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 CBP Regulations (19 CFR 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 Kristopher Burton at kristopher.burton@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division