N346400

N346400 November 14, 2025 CLA-2-68:OT:RR:NC:N1:128 CATEGORY: Classification TARIFF NO.: 7016.90.5000, 9903.02.20 Mr. Tyler Adams Acousthetics 4304 18th St San Francisco, CA 94114 RE: The tariff classification of acoustic panels from Germany. Dear Mr. Adams: In your letter dated March 2, 2025, you requested a tariff classification ruling. The merchandise under consideration is referred to as the Reapor Acoustic Panel. A sample was submitted with your ruling request and forwarded to the Customs and Border Protection Laboratory for analysis. This analysis has been completed. From the information you provided, the Reapor Acoustic Panel measures either 2 feet long by 2 feet wide or 2 feet long by 4 feet wide, and is 1 to 2 inches thick. It consists of 87-93% by weight expanded glass, with the balance consisting of sodium silicate. The panel is designed for use as ceiling or wall cladding in order to dampen noise in various settings such as classrooms, train stations, and shooting ranges. Laboratory analysis has determined that the panel is comprised of glass with a cellular or foam structure. In your ruling request you suggest classification of the Reapor Acoustic Panel in 6806.90.0010, Harmonized Tariff Schedule of the United States (HTSUS), as other mixtures and articles of heat-insulating, sound-insulating, or sound-absorbing mineral materials. However, the Reapor Acoustic Panel is made of glass, not of mineral materials. Classification in 6806.90.0010, HTSUS is precluded. The Reapor Acoustic Panel consists of different materials that are classifiable in different headings. The classification of merchandise under the HTSUS is governed by the General Rules of Interpretation (GRIs), taken in order. GRI 1 requires that classification be determined according to the terms of the headings and any relative section or chapter notes. In the event that goods cannot be classified solely on the basis of GRI 1, and if the heading and legal notes do not otherwise require the remaining GRIs will be applied, in the order of their appearance. GRI 3(b) provides, in relevant part, that composite goods which cannot be classified by reference to GRI 3(a) shall be classified as if they consisted of the material or component which gives them their essential character. The cellular/foam glass provides the essential character of the panel. The applicable subheading for the Reapor Acoustic Panel will be 7016.90.5000, HTSUS, which provides for “Paving blocks, slabs, bricks, squares, tiles and other articles of pressed or molded glass...multicellular or foam glass in blocks, panels, plates, shells or similar forms: Other: Other.” The general rate of duty will be 5 percent ad valorem. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of the European Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15 percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General duty rate. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.20, in addition to subheading 7016.90.5000, HTSUS, listed above. The tariffs and additional 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/. 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 Nicole Sullivan at nicole.d.sullivan@cbp.dhs.gov. Sincerely, (for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division

has been completed. From the information you provided, the Reapor Acoustic Panel measures either 2 feet long by 2 feet wide or 2 feet long by 4 feet wide, and is 1 to 2 inches thick. It consists of 87-93% by weight expanded glass, with the balance consisting of sodium silicate. The panel is designed for use as ceiling or wall cladding in order to dampen noise in various settings such as classrooms, train stations, and shooting ranges. Laboratory analysis has determined that the panel is comprised of glass with a cellular or foam structure. In your ruling request you suggest classification of the Reapor Acoustic Panel in 6806.90.0010, Harmonized Tariff Schedule of the United States (HTSUS), as other mixtures and articles of heat-insulating, sound-insulating, or sound-absorbing mineral materials. However, the Reapor Acoustic Panel is made of glass, not of mineral materials. Classification in 6806.90.0010, HTSUS is precluded. The Reapor Acoustic Panel consists of different materials that are classifiable in different headings. The classification of merchandise under the HTSUS is governed by the General Rules of Interpretation (GRIs), taken in order. GRI 1 requires that classification be determined according to the terms of the headings and any relative section or chapter notes. In the event that goods cannot be classified solely on the basis of GRI 1, and if the heading and legal notes do not otherwise require the remaining GRIs will be applied, in the order 

of their appearance. GRI 3(b) provides, in relevant part, that composite goods which cannot be classified by reference to GRI 3(a) shall be classified as if they consisted of the material or component which gives them their essential character. The cellular/foam glass provides the essential character of the panel. The applicable subheading for the Reapor Acoustic Panel will be 7016.90.5000, HTSUS, which provides for “Paving blocks, slabs, bricks, squares, tiles and other articles of pressed or molded glass...mult