The tariff classification of a well seal kit from Canada

N360465 April 16, 2026 CLA-2-40:OT:RR:NC:N5:137 CATEGORY: Classification TARIFF NO.: 4016.93.5050 Paul Diamond Dominion Customs Consultants 1595 16th Avenue, Suite 202 Richmond Hill, Ontario L48 3N9 Canada RE: The tariff classification of a well seal kit from Canada Dear Mr. Diamond: In your letter dated April 6, 2026, you requested a tariff classification ruling on behalf of your client, Boshart Industries. The product under consideration is Part # WSP6012, Single Hole Plastic Well Seal-6”x1-¼” (Well Seal). The well seal is a kit consisting of a top and bottom plate composed of acrylonitrile-butadiene-styrene (ABS) plastic, a gland composed of styrene butadiene (SBR) rubber, grommets, bolts, and nuts. The rubber gland is sandwiched between the top and bottom plates. The three pieces contain holes for fasteners. The bolts and nuts are inserted through the holes and when tightened the plastic plates compress the rubber gland expanding it onto the sides of the well to create the seal. The plastic plates and rubber gland also include holes to accommodate grommets that allow pipe and wiring to pass through the seal into the well. In your submission, you proposed that this well seal kit should be classified under subheading 3926.90.4590, Harmonized Tariff Schedule of the United States (HTSUS), which provides for plastic gaskets, washers, and other seals. While we agree that this product would qualify as a General Rule of Interpretation 3(b) set, we disagree that the plastic plates would impart the essential character. Rather, we hold the opinion that it is the rubber gland, which is compressed to form the seal within the well, that would provide the classification to this kit. The applicable subheading for the well seal kit will be 4016.93.5050, HTSUS, which provides for other articles of vulcanized rubber other than hard rubber: other: gaskets, washers and other seals: other: other. The general rate of duty will be 2.5 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 Christina Allen at julie.c.allen@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division