The tariff classification and country of origin of computer server cabinets returned to the United States (U.S.)

N361684June 2, 2026CLA-2-94:RR:NC:N5:433 CATEGORY: Classification; Origin TARIFF NO.: 9403.10.0040; 9801.00.1092 Qianli ZhouFrontier Trade Solutions50 Brompton Rd 2DGreat Neck, NY 11021RE: The tariff classification and country of origin of computer server cabinets returned to the United States(U.S.)Dear Qianli Zhou:In your letter dated May 20, 2026 , you requested a tariff classification ruling on behalf of HOX IDC CVGInc. In lieu of samples, technical and illustrative literature, a product description, and a manufacturingsynopsis were provided for review.The “Digital Data Center Server Cabinet” is a series of floor-standing, unequipped, steel sheet metal storagecabinet racks. Four (4) wheel casters are located at the base of each cabinet rack.The dimensions of each cabinet rack are approximate 45.67"in length, 27.56" in width, 98" in height, and will weigh approximately 448 lbs. Information provided states, “[T]he Digital Data Center Server Cabinet is to be used as a clustered cabinet system for storing stacked servers in large data centers that provide cloud and other computingservices.”The cabinet racks contain no internal electronic components or electronic subassemblies. The ruling request outlines an operation wherein one (1) steel top plate, one (1) steel base plate, six (6) steelside panels, two (2) steel upright columns, copper busbars, and plastic components will be sourced inThailand. The material components will be shipped and exported to the U.S.In the U.S., no additional raw material components will be locally sourced. The manufacturing process undertaken in the U.S. involves (1) mechanical robotic arms will weld the cabinet rack frame components, (2) manual welding will occur withhandheld tools, (3) mechanical automatic polishing and grinding will occur to remove excess materials,smooth, and refine edges, (4) additional polishing and grinding will occur to remove excess materials,smooth, and refine edges using handheld laser welders and handheld angle grinders, (5) the assembledcabinet will be measured according to manufacturer specifications using handheld shaping tools andinstruments, (6) heat resistant rubber plugs will be mounted in precise locations throughout the cabinet, (7)mechanical robotic arms will be used to move, position, reposition, load, and unload the assembled cabinetracks during spray painting and heat treatment, (8) inspection of internal, external and diagonal dimensions,(9) electric screwdrivers are used to create grounding holes and installation of support brackets, and (10) the complete cabinet rack will undergo final inspection, packaging, and then stored in a warehouse.Photographs of these processes were provided.Further, information provided states, “After production in the US, the finished products were exported to abonded warehouse in Mexico for storage where no processing or change was conducted on the product. Someof these stored Digital Data Center Server Cabinets that were unsold in Mexico are now being imported backinto the US to meet further US customers’ demands.”The ruling request seeks classification of the subject merchandise in subheading 9403.10.0040, HarmonizedTariff Schedule of the United States (HTSUS), and a secondary tariff classification of 9801.00.10, HTSUS. The applicable subheading for the subject merchandise will be 9403.10.0040, HTSUS, which provides for“Other furniture and parts thereof: Metal furniture of a kind used in offices:Other.” Eligibility for preferential treatment under the USMCA:The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30,2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of theUSMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note ("GN")11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good isan originating good for purposes of the USMCA. GN 11(b) states:For the purposes of this note, a good imported into the customs territory of the United States from theterritory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tarifftreatment provided for in the applicable subheading and quantitative limitations set forth in the tariff scheduleas a "good originating in the territory of a USMCA country" only if-(i) the good is a good wholly obtained or produced entirely in the territory of one or more USMCAcountries;(ii) the good is a good produced entirely in the territory of one or more USMCA countries,exclusively from originating materials;(iii) the good is a good produced entirely in the territory of one or more USMCA countries usingnon-originating materials, if the good satisfies all applicable requirements set forth in this note(including the provisions of subdivision (o));Since the “Digital Data Center Server Cabinet” contains non-originating materials, it is not considered a goodwholly obtained or produced entirely in a USMCA country under GN 11(b)(i), nor is the “Digital DataCenter Server Cabinet” produced exclusively from originating materials per GN 11(b)(ii). Thus, we mustdetermine whether the piece of furniture qualifies under GN 11(b)(iii). As previously noted, the “Digital DataCenter Server Cabinet” is classified under subheading 9403.10.0040, HTSUS, the applicable rule of origin isGN 11(o), HTSUS, which provides, in relevant part:Chapter 944. (A) A change to subheadings 9403.10 through 9403.89 from any other chapter; or (B) A change to subheadings 9403.10 through 9403.89 from subheading 9403.90, whether or notthere is also a change from any other chapter, provided there is a regional value content of not lessthan:(1) 60 percent where the transaction value method is used; or (2) 50 percent where the net cost method is used.Under GN11(o), Rule 4 and criterion “A” to Chapter 94 HTSUS, the non-originating materials (steel topplate, steel base plate, steel side panels, steel upright columns, copper busbars, and plastic components fromThailand) undergoes the permissible tariff shift. In view of the facts provided, the subject merchandisedescribed above qualifies for USMCA preferential tariff treatment, because it will meet the requirements ofHTSUS General Note 11(b)(iii)(o). The subject merchandise will therefore be entitled to a free rate of duty under the USMCA upon compliance with all applicable laws, regulations, and agreements.Country of Origin:Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, everyarticle of foreign origin imported into the United States shall be marked in a conspicuous place as legibly,indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as toindicate to the ultimate purchaser in the United States, the English name of the country of origin of thearticle. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able toknow by an inspection of the marking on the imported goods the country of which the goods is the product.The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, byknowing where the goods were produced, be able to buy or refuse to buy them, if such marking shouldinfluence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940).Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country ofmanufacture, production, or growth of any article of foreign origin entering the United States. Further workor material added to an article in another country must effect a substantial transformation in order to rendersuch other country the “country of origin” within the meaning of the marking laws and regulations.Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and otherUSMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth insections 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respectto goods imported from Canada and Mexico. Section 102.11 provides a required hierarchy for determiningthe country of origin of a good for marking purposes, with the exception of textile and apparel goods whichare subject to the provisions of 19 CFR 102.21. See 19 CFR 102.11.Applied in sequential order, 19 CFR 102.11(a) provides that the country of origin of a good is the country inwhich:(1) The good is wholly obtained or produced;(2) The good is produced exclusively from domestic materials; or(3) Each foreign material incorporated in that good undergoes an applicable change in tariffclassification set out in Part 102.20 and satisfies any other applicable requirements of that section, andall other applicable requirements of these rules are satisfied.As the subject merchandise is not wholly obtained or produced in a single country, Rule (1) of § 102.11(a)(1)is inapplicable. As the subject merchandise is not produced exclusively from domestic materials, Rule (2) of§ 102.11(a)(2) is inapplicable. Accordingly, Rule (3) applies.Section 102.20 sets forth specific rules by tariff classification. The pertinent tariff shift rule for subheading9403.10, HTSUS, states:A change to subheading 9403.10 through 9403.89 from any other subheading outside that group,except from subheading 9401.10 through 9403.89, and except from subheading 9401.91 through9401.99 or 9403.91 through 9403.99, when that change is pursuant to General Rule of Interpretation2(a). General Rule of Interpretation 2(a) (“GRI 2(a)”) states:Any reference in a heading to an article shall be taken to include a reference to that article incompleteor unfinished, provided that, as entered, the incomplete or unfinished article has the essentialcharacter of the complete or finished article. It shall also include a reference to that article complete orfinished (or falling to be classified as complete or finished by virtue of this rule), entered unassembledor disassembled.In view of the facts provided, the incomplete and unfinished metal components from Thailand does have theessential character of the finished article and additional manufacturing and production will occur in theUnited States, GRI 2(a) does apply. Further, since the change from 9403.10 through 9403.89 HarmonizedTariff Schedule (HTS) will occur as a result of manufacturing and production in the United States, the“Digital Data Center Server Cabinet” will undergo the required change in tariff classification. Therefore, thetariff shift requirement of section 102.11(a)(3) is met. The country of origin of the “Digital Data CenterServer Cabinet” for origin and marking purposes is the United States.Additionally, the applicable subheading for the subject merchandise will be 9801.00.1092, HTSUS, whichprovides for “Products of the United States when returned after having been exported, or any other productswhen returned within 3 years after having been exported, without having been advanced in value or improvedin condition by any process of manufacture or other means while abroad: Other: Articles provided for inchapter 94: Articles provided for in headings 9401, 9402 or 9403,” provided that all of the conditionsdelineated in U.S. Note 1, Chapter 98, Subchapter XXII, HTSUS are satisfied.The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenienceand are subject to change. The text of the most recent HTSUS and the accompanying duty rates are providedat https://hts.usitc.gov/.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to theclassification stated above, the merchandise covered by this ruling may also need to be reported with eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems 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 asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Dharmendra Lilia at dharmendra.lilia@cbp.dhs.gov. Sincerely, (for)James P. ForkanDirectorNational Commodity Specialist Division