The tariff classification, country of origin, and trade program status of a prefabricated building structure

N359753 April 7, 2026 CLA-2-94:OT:RR:NC:N5:130 CATEGORY: Classification TARIFF NO.: 9406.90.0130 Mr. LeVaughn Kaopio Novus Universal, Inc. 500 Alakawa Street, #105 Honolulu, HI 96817 RE: The tariff classification, country of origin, and trade program status of a prefabricated building structure Dear Mr. Kaopio: In your letter, dated February 24, 2026, you requested a binding tariff classification, country of origin, and applicability of trade programs ruling on a prefabricated building structure. The request was returned to you for additional information, which was received by this office on March 16, 2026. Product information and diagrams were submitted for our review. The product under consideration is a prefabricated building structure for residential construction. The structure is constructed of cold-formed steel structural members including wall studs, tracks, floor joists, and roof trusses. The wall panels are constructed of cold-formed steel studs and tracks with magnesium oxide sheathing boards and various types of insulation. The floor structure is constructed of cold-formed steel joists. You state that “the prefabricated wall panels incorporate exterior sheathing, insulation systems, and mechanical, electrical, and plumbing rough-in components prior to shipment. Exterior wall panels are configured to receive exterior cladding on site, while interior finishes are completed after installation and final utility connections.” You state that “(e)lectrical conduit and wiring, plumbing piping, and HVAC pathways may be installed within the cold formed steel wall cavities during panel fabrication.” You also state that interior finishes are installed after the structural building has been erected in the U.S. The structures are not imported with furniture or appliances. The components are entered together ready to assemble into a prefabricated building structure. The materials are not adapted to general use. The units are not modular units that are assembled together to form a larger structure. Note 4 to Chapter 94, Harmonized Tariff Schedule of the United States (HTSUS) defines “prefabricated buildings”: For the purposes of heading 9406, the expression "prefabricated buildings" means buildings which are finished in the factory or put up as elements, entered together, to be assembled on site, such as housing or worksite accommodation, offices, schools, shops, sheds, garages or similar buildings. The Explanatory Notes to the Harmonized System for Chapter 94 set for that prefabricated buildings are in the form of - complete buildings, fully assembled, ready for use; - complete buildings, unassembled; - incomplete buildings, whether or not assembled, having the essential character of prefabricated buildings. In the case of buildings presented unassembled, the necessary elements may be presented partially assembled (for example, walls, trusses) or cut to size (beams, joists, in particular) or, in some cases, in indeterminate or random lengths for cutting on the site (sills, insulation, etc.). The instant units are finished in the factory and entered together to be assembled onsite into housing units. They include trusses, wall panels (with steel framing), and joists. While the finishing is completed in the United States, the imported goods have the essential character of prefabricated buildings. The applicable subheading for the prefabricated building structures will be 9406.90.0130, HTSUS, which provides for Prefabricated buildings: Other: Of metal: Other. The general rate of duty will be 2.9 percent ad valorem. While you request a country of origin and trade program status ruling, you have provided insufficient information for those determinations. We must know each manufacturing operation and the country in which each operation takes place. Purchase of materials in a particular country does not confer country of origin. I n accordance with Title 19, Code of Federal Regulations, Section 177.7, “Moreover, no ruling letter will be issued with regard to transactions or questions which are essentially hypothetical in nature or in any instance in which it appears contrary to the sound administration of the Customs and related laws to do so.” We cannot provide a determination on possible countries of origin. 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 Laurel Duvall at laurel.duvall@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division