The classification of nonalloy steel posts from India

N362807 July 20, 2026 CLA-2-72:OT:RR:NC:N5:117 CATEGORY: Classification TARIFF NO.: 7216.91.0010 Lowell G. Defrance Navia USA LLC 200 North Martingale Road, Suite 400 Schaumburg, IL 60513 RE: The classification of nonalloy steel posts from India Dear Mr. Defrance: In your letter dated July 1, 2026, you requested a tariff classification ruling on behalf of your client, Ideematec. The products under consideration are sigma shaped, nonalloy steel zinc coated posts/profiles with holes drilled along their length. These cold-rolled steel posts will measure from 150 - 180 mm in height, 80 - 100 mm in width, and 4.1 - 5.3 meters in length. The steel posts will be used in utility-scale solar farms. In your submission, you propose that the steel posts may be classified in subheading 8479.90.95, Harmonized Tariff Schedule of the United States (HTSUS), covering other parts of machines of heading 8479, HTSUS. We disagree. While complete solar tracker systems generally fall within heading 8479, the separately imported steel posts are more specifically provided for elsewhere in the tariff schedule. See, e.g., NY Ruling Letter N308324, dated January 9, 2020. Accordingly, classification in heading 8479 is inappropriate. In the alternative, you suggest that the steel posts are properly classified under subheading 7308.90.6000, HTSUS, which provides for Structures (excluding prefabricated buildings of heading 9406) and parts of structures (for example, bridges and bridge sections, lock gates, towers, lattice masts, roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, shutters, balustrades, pillars and columns) of iron or steel; plates, rods, angles, shapes, sections, tubes and the like, prepared for use in structures, of iron or steel: Other: Columns, pillars, posts, beams, girders and similar structural units: Other. We disagree. Based on the information provided, the subject posts are specifically provided for elsewhere in the tariff and therefore precluded from classification in heading 7308, HTSUS. We turn to the Explanatory Notes (ENs) of the HTSUS for clarification as to the proper classification of the merchandise concerned. When interpreting and implementing the HTSUS, the ENs of the Harmonized Commodity Description and Coding System may be utilized. The ENs, while neither legally binding nor dispositive, provide a guiding commentary on the scope of each heading, and are generally indicative of the proper interpretation of the HTSUS. CBP believes the ENs should always be consulted. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989). EN 72.16 provides, in pertinent part: Angles, shapes and sections are defined in Note 1(n) to this Chapter. The heading includes goods which have been cold-formed or cold-finished (by cold-drawing, etc.) and also covers angles, shapes and sections made by forming on a roll type machine or by forming sheets, plates or strip on a press. The products of this heading may have been subjected to working such as drilling, punching or twisting or to surface treatment such as coating, plating or cladding - see Part IV (C) of the General Explanatory Note to this Chapter, provided they do not thereby assume the character of articles or of products falling in other headings. The steel posts under consideration are shaped into an angle, shape, or section conforming to heading 7216. Additionally, the drilling of these posts constitutes a further working operation permitted under heading 7216. Therefore, it is the opinion of this office that the steel posts are classified in heading 7216, HTSUS. (See Headquarters Ruling HQ 965792 dated March 31, 2003). The applicable subheading for the sigma shaped, nonalloy steel zinc coated posts will be 7216.91.0010, HTSUS, which provides for Angles, shapes and sections of iron or nonalloy steel: Angles, shapes and sections, not further worked than cold-formed or cold-finished: Other: Cold-formed or cold-finished from flat-rolled products: Drilled, notched, punched or cambered. The rate of duty will be free. 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, contact National Import Specialist Denise Hopkins at denise.hopkins@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division