In ruling NY N319909 (July 8, 2021), Customs and Border Protection (CBP) discussed the classification of a cast aluminum safe handle and an extruded aluminum safe hinge profile. The handle under examination is approximately 4.7 inches long, 2.4 inches tall, and 1.5 inches wide, with a round base that is 1.5 inches in diameter. Additionally, the handle is attached to a steel spindle that is 3.82 inches long with a roll pin that is 0.375 inches long. The part’s intended purpose of importation is for assembly, where it would be “inserted from the front of the safe door through the combination lock escutcheon and the clutching mechanism and then secured by an E-clip.” The handle allows users to retract the safe’s bolts when the lock is released. However, attempts to force or pry the handle will cause the E-clip to fail and disengage the handle from working.
The safe hinge profile under consideration is also an imported component intended for assembly. It is 6.16 inches long and is drilled with unthreaded holes. The hinge would be surface mounted to the right side of the safe’s door using self-tapping screws – which engage with the predrilled unthreaded holes. Two L-brackets with loops would be welded to the right edge of the safe opening and knurled hinge pins are forced through the holes of the brackets and into the hinge profile on either side. The hinge assembly’s configuration also allows for there to be an uninterrupted gasket surrounding the door and safe opening. The hinge profile would be imported without the knurled pins, self-tapping screws, or L-brackets to connect the hinge to the door and body of the safe.
In its decision, CBP determined that the applicable subheading for the safe handle and hinge is 8303.00.0000, HTSUS, which provides for “Armored or reinforced safes, strong-boxes and doors and safe deposit lockers for strong-rooms, cash or deed boxes and the like, and parts thereof, of base metal.” CBP referred to Chapter 83, Note 1 in its decision – which states “For the purposes of this chapter, parts of base metal are to be classified with their parent articles.” The rate of duty is 3.8% ad valorem.
Additionally, pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, Chinese products under subheading 8303.00.0000, HTSUS, unless specifically excluded, are subject to an additional 25% ad valorem duty rate. As such, the chapter subheading 9903.88.03 must be reported in addition to subheading 8303.00.0000, HTSUS, for the door handle.