The tariff classification of a plastic lid assembly from China.

N355938 December 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 Gregory J. Derian Derian Enterprises, Inc. 395 Hasbrouck Boulevard Oradell, NJ 07649 RE: The tariff classification of a plastic lid assembly from China. Dear Mr. Derian: In your letter dated November 11, 2025, you requested a tariff classification ruling. Images were submitted in lieu of a sample. The product under consideration is described as an injection molded high-density polyethylene (HDPE) plastic screw-top lid assembly that features an integrated screen. It is intended to go on top of a plastic pail that has been modified to function as a motor oil drain pan and a fluid transfer container. The lid has a sealing surface designed to accept a nitrile rubber O-ring to prevent oil spilling during transport. The integrated screen will provide a separation barrier, prevent unwanted items from falling into the drained oil, and act as a drain shelf to drain used oil filters. In your submission, you ask whether these lids can be considered “components for assembly” if they are imported exclusively for integration with pails made in the United States. We note that there is not a specific classification for “components for assembly.” Further, we must look to the condition of the product at time of importation and not its intended use once in the United States. Articles may be classified as parts or accessories to specific goods when the tariff language provides for them, but in this instance, there is not one of these provisions for plastic pails and buckets. As this lid assembly would be considered an article of plastic, and as it is 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 10 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 15 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, contact National Import Specialist Kristopher Burton at kristopher.burton@cbp.dhs.gov. Sincerely, (for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division