RE: The tariff classification of stainless steel refrigerator door panels from Taiwan

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365686 October 21, 2026 CLA-2-72:OT:RR:NC:N5:117 CATEGORY: Classification TARIFF NO.: 7219.90.0080 George R. Tuttle, III Tuttle Law Offices 3950 Civic Center Dr., Suite 102 San Rafael, California 94903 RE: The tariff classification of stainless steel refrigerator door panels from Taiwan Dear Mr. Tuttle: In your letter dated October 2, 2026, you requested a tariff classification ruling on behalf of your client, Millennia Stainless Inc. The products under consideration are stainless steel sheet panels and are identified as Part Numbers 245D1316P016 and 245D1316P01. These panels are made from cold-rolled Grade 430 stainless steel sheets with a #4 polished finish and drilled with one or two holes. Part Number 245D1316P017 forms the exterior stainless steel panel for the lower fresh food door and measures 47.67 inches (1210.8 mm) in width x 37.26 inches (946.4 mm) in length x 0.022 inches (0.56 mm) in thickness. Part Number 245D1316P017 forms the exterior stainless steel panel for the upper freezer door and measures 29.71 inches (754.63 mm) x 37.26 inches (946.4 mm) in length x 0.022 inches (0.56 mm) in thickness. Your ruling request seeks classification of the current two-hole configuration and the proposed one-hole configuration. In your letter, you suggest classifying the articles in accordance with GRI 2(a) under subheading 8418.99.8050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Refrigerators, freezers and other refrigerating or freezing equipment, electric or other; heat pumps, other than the air conditioning machines of heading 8415; parts thereof: Parts: Other: Other: Other: Parts of combined refrigerator-freezers fitted with separate external doors and parts of household type refrigerators. We disagree. GRI 2(a) extends the scope of the HTSUS headings to include unfinished parts, provided the unfinished parts have the essential character of the finished parts. GRI 2(a) further states that: Any reference in a heading to an article shall be taken to include a reference to that article incomplete or unfinished, provided that, as entered, the incomplete or unfinished article has the essential character of the complete or finished article. It shall also include a reference to that article complete or finished (or falling to be classified as complete or finished by virtue of this rule), entered unassembled or disassembled. In addition, Explanatory Note (EN) II under GRI 2(a) states that: The provisions of this Rule also apply to blanks unless these are specified in a particular heading. The term “blank” means an article, not ready for direct use, having the approximate shape or outline of the finished article or part, and which can only be used, other than in exceptional cases, for completion into the finished article or part. Semi-manufactures not yet having the essential shape of the finished articles (such as is generally the case with bars, discs, tubes, etc.) are not regarded as “blanks.” Accordingly, two criteria which an article must meet in order to be classified as a blank for purposes of GRI 2(a) are (1) it must possess the approximate shape or outline of the finished article, and (2) the sole use must be for completion into the finished article. In this case, GRI 2(a) is not applicable to the panels when imported in a pre-machined condition, as they do not meet the criteria stated above. It is not evident that the panels possess the approximate shape or outline of a finished refrigerator door; rather, their basic rectangular and square shape does not exclusively correspond to a refrigerator door and can be adapted (cut, reworked, and trimmed) or used for other purposes. The fact that the panels have been cut to length and width does not make them unfinished parts. In their pre-machined condition, there is nothing to suggest that these panels are restricted solely to being made into refrigerator doors. Each panel requires extensive post-importation processing, such as notching, folding, inserting end caps, and the addition of a handle, an inner liner, and insulation foam, before it becomes readily recognizable as the finished article. Therefore, the panels do not have the essential character of a complete or finished good classified within heading 8418. The applicable subheading for the stainless steel refrigerator door panels, Part Numbers 245D1316P016 and 245D1316P017, whether imported in the one-hole or two-hole configuration, will be 7219.90.0080, HTSUS, which provides for Flat-rolled products of stainless steel, of a width of 600 mm or more: Other: Other: Other: Other. The general rate of duty will be free. 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/current. 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 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