The tariff classification of sprinklers from China

N358979 March 16, 2026 CLA-2-76:OT:RR:NC:N4:422 CATEGORY: Classification TARIFF NO.: 7615.10.9100 Ms. Sandra Welsh Orbit Irrigation Products, LLC 845 N Overland Road North Salt Lake, UT 84054 RE: The tariff classification of sprinklers from China Dear Ms. Welsh: In your letter dated February 18, 2026, you requested a tariff classification ruling. Photographs and the percentage cost and weight breakdown of materials were also submitted with your request. The items concerned are referred to as a 3-Arm metal telescoping sprinkler on metal step spike, Orbit part no. 27770 and a MAX rotating sprinkler, Orbit part no. 56071. Both sprinklers are used around the home for watering the grass and gardens. Item 1 is a 3-Arm metal telescoping sprinkler on metal step spike, Orbit part no. 27770. The item contains an aluminum 3-arm sprinkler, aluminum fittings for the sprinkler and spike, an aluminum Hi-Rise shaft, an aluminum step spike, a polypropylene lock fitting for the Hi-Rise shaft, an aluminum connection, and a polypropylene hose cap. The telescoping riser is customizable and adjustable in height from 21.37 inches to 33.37 inches, covering up to 2,000 square feet based on the selected height, and features a 360-degree pattern. The aluminum easy step spike has a built-in flow-through aluminum coupling, allowing water to be connected to the sprinkler or multiple sprinklers to be added. The polypropylene hose cap on one side of the coupling can be removed when additional sprinklers are added. The aluminum sprinkler has three arms and sprays in a circular pattern. The sprinkler has no valve and is controlled by water pressure. Item 2 is a MAX rotating sprinkler, Orbit part no. 56071. The item has an aluminum base, is made of acrylonitrile butadiene styrene (ABS) plastic material, and a zinc female swivel retainer. Each arm of the sprinkler has three adjustable spray nozzles. A fan spray for close range and heavy coverage, a shower pattern for a lighter, softer spray, and a four-nozzle spray. The sprinkler was designed with a flow-through coupling to allow multiple sprinklers to be attached. The flow-through coupling has brass threaded couplings at each end to attach to a garden hose, with a removable cap that allows additional sprinklers. The sprinkler has no valve and is controlled by water pressure. The 3-Arm metal telescoping sprinkler on metal step spike, Orbit part no. 27770 and the MAX rotating sprinkler, Orbit part no. 56071, are both constructed of different materials that are classifiable in different headings. The classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is governed by the General Rules of Interpretation (GRIs), taken in order. GRI 1 requires that classification shall be determined according to the terms of the headings and any relative section or chapter notes. In the event that goods cannot be classified solely on the basis of GRI 1, and if the heading and legal notes do not otherwise require the remaining GRIs will be applied, in the order of their appearance. GRI 3(b) provides, in relevant part, that composite goods which cannot be classified by reference to GRI 3(a) shall be classified as if they consisted of the material or component which gives them their essential character. As the sprinklers are composite goods, we must apply rule GRI 3(b), which provides that composite goods are to be classified according to the component that gives the goods their essential character. Explanatory Note (EN) VIII to GRI 3(b) explains that “the factor which determines essential character will vary as between different kinds of goods. It may, for example, be determined by the nature of the material or component, its bulk, quantity, weight or the use of the goods.” We must determine which component imparts the essential character to the sprinklers in question. In our opinion, the role of the constituent materials or components in relation to the use of the good is the portion that imparts the essential character. In this case, the metal components impart the essential character. Section XV, Note 7 of the HTSUS states that the classification of composite articles of base metal containing two or more base metals are to be treated as articles of the base metal that predominates by weight over each of the other metals. Based on the information provided to our office, the predominant metal by weight is aluminum. Therefore, the articles in question are classifiable as articles of aluminum. In your letter, you suggest the applicable classification for the sprinklers to be classified in heading 8424, HTSUS. We disagree. In order to be classified in heading 8424, the sprinklers must have a mechanical component. In this case, both of the sprinklers are activated when the water pressure is added. While the sprinklers may rotate, they only do so based on the water pressure. Sprinklers classified in heading 8424, such as impact sprinklers, would have a component such as a spring that allows the sprinkler to direct the water in certain ways. Sprinklers that solely run on the power of the water pressure are classified by constituent material. Accordingly, heading 8424 is excluded from consideration. The applicable subheading for the 3-Arm metal telescoping sprinkler on metal step spike, Orbit part no. 27770 and the MAX rotating sprinkler, Orbit part no. 56071 will be 7615.91.0000, HTSUS, which provides for “Table, kitchen or other household articles and parts thereof, of aluminum; sanitary ware and parts thereof, of aluminum: Table, kitchen or other household articles and parts thereof; pot scourers and scouring or polishing pads, gloves and the like: Other: Other.” The general rate of duty will be 3.1 percent ad valorem. The 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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 Dana L. Giammanco at dana.l.giammanco@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division