N349448

N349448 June 10, 2025 CLA-2-85:OT:RR:NC:N2 209 CATEGORY: Classification TARIFF NO.: 8541.90.0000, 9903.01.24, 9903.01.32, 9903.91.05 Patrick Chen Jiangsu Worldlight New Material Co.,Ltd. No. 89, Gangzhong Road, Xinbei District Changzhou 213022 China RE: The tariff classification of composite frames for photovoltaic (PV) solar panels from China Dear Mr. Chen: In your letter dated May 27, 2025, you requested a tariff classification ruling. The items concerned are composite structural frames used in the manufacture/assembly of photovoltaic (PV) solar panels. These particular frames are produced using a pultrusion process that combines continuous glass fibers and polyurethane resin to form lightweight yet rigid profiles (fiber-reinforced polymer composite frames). The composite frames serve the same functional purpose as traditional aluminum frames, as they encase or frame the bare outer edge of the laminated solar panel, providing support and rigidity. They form an integral part of the finished solar panel/module. At time of import into the United States, the frames/profiles are cut to size. They consist of two long side pieces and two shorter top/bottom pieces (actual size depends on the specific model). They incorporate 45-degree mitered cuts at each corner, and have pre-drilled holes and slots. The applicable subheading for the composite structural solar panel frames (fiber-reinforced polymer composite frames) will be 8541.90.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Semiconductor devices (for example, diodes, transistors, semiconductor-based transducers); photosensitive semiconductor devices, including photovoltaic cells whether or not assembled in modules or made up into panels; light-emitting diodes (LED), whether or not assembled with other light-emitting diodes (LED); mounted piezo-electric crystals; parts thereof.” The general rate of duty will be Free. 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 8541.90.0000, 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. At this time products from all countries will be subject to an additional 10 percent ad valorem rate of duty. Your product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.32, in addition to subheading 8541.90.0000, HTSUS, listed above. Pursuant to U.S. Note 31 (f) to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8541.90.0000, HTSUS, unless specifically excluded, are subject to an additional 50 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.91.05, in addition to subheading 8541.90.0000, 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, 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/remedies/301-certain-products-china, 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 Steven Pollichino at steven.pollichino@cbp.dhs.gov. Sincerely, (for) 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 Steven Pollichino at steven.pollichino@cbp.dhs.gov. 
Sincerely,
 (for) Steven A. Mack Director National Commodity Specialist Division