N347487

N347487 April 24, 2025 CLA-2-95:OT:RR:NC:N4:424 CATEGORY: Classification TARIFF NO.: 9506.39.0080; 9903.01.24; 9903.01.63 ; 9903.8815 Marilyn Santos Supreme International 3000 NW 107th Avenue Miami, FL 33172 RE: The tariff classification of a 4 pack of Putting Gates, item AVAFF008, from China. Dear Ms. Santos: In your letter submitted on March 25, 2025, you requested a tariff classification ruling. A sample of a 4 pack of Putting Gates, item AVAFF008, was received with your inquiry. The putting gates are composed of aluminum with stakes on each end for easy insertion into the ground. Each gate pack contains 50mm, 55mm, 65mm and 70mm putt alignment gates. Putting gates are golf training aids that are used to develop putting alignment and stroke consistency. The putting gates are used to create a narrow pathway for the ball to roll through, training golfers to be more accurate and consistent with their putting stroke. These gates help golfers visualize the correct line for the putt and are intended for outdoor use. The applicable subheading for the 4 pack of Putting Gates, item AVAFF008, will be 9506.39.0080, Harmonized Tariff Schedule of the United States, (HTSUS), which provides for "Articles and equipment for general physical exercise…athletics, other sports…parts and accessories thereof: Golf clubs and other golf equipment; parts and accessories thereof: Other." The rate of duty will be 4.9% ad valorem. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition to subheading 9506.39.0080, HTSUS, listed above. 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. Products of China, including Hong Kong and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, 9903.01.63, in addition to subheading 9506.39.0080, HTSUS, listed above.? You inquired whether the Section 232 additional duties on certain derivative aluminum products applies to the 4 pack of Putting Gates, item AVAFF008. ?Articles of subheading 9506.39.0080, HTSUS, are not among those listed in Annex 1 to Presidential Proclamation 10895. Pursuant to U.S. Note 31 (b) to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9506.39.0080, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 9506.39.0080, HTSUS, listed above. The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively. 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 Roseanne Murphy at roseanne.j.murphy@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division

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 Roseanne Murphy at roseanne.j.murphy@cbp.dhs.gov. 
Sincerely,
 Steven A. Mack Director National Commodity Specialist Division