N351539

N351539 August 19, 2025 CLA-2-83:OT:RR:NC:N5:121 CATEGORY: Classification TARIFF NO.: 8302.42.3065; 7318.15.8045; 7318.14.1060; 7318.29.0000; 3926.90.9989; 8204.11.0060; 9903.01.24; 9903.81.90; 9903.01.33; 9903.01.25; 9903.88.03; 9903.88.15 Melvin Archie NOA Medical Industries LLC 801 Terry Lane Washington, MO 63090 RE: The tariff classification of hardware packs from China Dear Mr. Archie: In your letter dated July 21, 2025, you requested a tariff classification ruling. The articles under consideration are described as hardware packs: Item 7000049BEI — Side Rail Assembly for Pan 3000 and 3250 Long Term Care Bed; and Item 7000050BEI — Side Rail Assembly for Pan 3500 Long Term Care Bed. The hardware packs consist of the following components: Item 3040078, 2 steel wire corner mattress retainers. These connect to each corner of the bed frame to hold the mattress in place. Item 5340022BEI, 4 steel headboard and footboard brackets for Quick Release - horizontal. These are straight metal columns that will be inserted into the vertical bracket. Together they will function to attach the headboard or footboard to the bed. Item 5340023BEI, 4 steel headboard and footboard brackets for Quick Release - Vertical. These are L-shaped metal columns into which the horizontal bracket will be placed. Together they will function to attach the headboard or footboard to the bed. Item 4010015, 8 Cap Insert - Flat Head - 1/4-20x 16 mm (Honey Bronze). These are bronze cap inserts that function to cover the hex screws that attach the headboard or footboard to their respective brackets. Item 4000197 8 Hex screws - Cap, PPH, Steel, Zinc Plated - 1/4-20 x 1 1/2". These are steel, pan head, socket cap screws that measure .25 inches in diameter. Item 4000207, 1 Screw - Sheet Metal, PFH, Steel, Zinc Plated - #10-12 x 3/4". These sheet metal screws measure approximately .190 inches (4.83 mm) in diameter and 3/4 inches long. They have a Phillips head drive with a gimlet point. Item 5340005, 4 Pin and Cable - Quick Release Steel Hd/Ft board - The quick release pins are made of steel, are non-threaded, and have a spring-loaded locking ball mechanism on one end and a steel wire loop attached at the top. A steel wire cable with a bracket for a screw is attached to the loop. Item 4000036, 4 Insert - Plastic "IV" Socket - These plastic sockets are for IV poles and are put on the top end of each headboard and footboard bracket. Item 4040025, 1 Clamp - Adjustable Nylon Cable - These are used to hold a cable in place. A 4 mm hex wrench. These wrenches are used to tighten the hex screws. These packs consist of only some of the hardware used to complete the specified beds. The packs are typically imported with the entire bed, but this request concerns the classification of the hardware packs when imported separately. The Explanatory Notes, which constitute the official interpretation of the Harmonized Tariff Schedule of the United States (HTSUS) at the international level, state in Note (X) to Rule 3 (b) that the term "goods put up in sets for retail sale" means goods which: (a) consist of at least two different articles which are prima facie, classifiable in different headings; (b) consist of products or articles put up together to meet a particular need or carry out a specific activity; (c) are put up in a manner suitable for sale directly to users with repacking The hardware packs do not meet the qualifications of "goods put up in sets for retail sale." The components of the set consist of at least two different articles which are, prima facie, classifiable in different headings, and they are packed for sale directly to users without repacking, but they are not put up together to meet a particular need or carry out a specific activity. While the mattress retainers and headboard and footboard brackets are used on a long-term care bed, their specific functions (retaining the mattress and connecting the headboard /footboard) are unrelated. An interdependent relationship does not exist between the two articles. Therefore, when imported separately from the beds, the components of these hardware packs are separately classifiable. The applicable subheading for Item 3040078, 2 steel wire corner mattress retainers; Item 5340022BEI, 4 steel head and footboard brackets for Quick Release - horizontal; Item 5340023BEI, 4 steel headboard and footboard brackets for Quick Release - Vertical; and Item 4010015, 8 Cap Insert - Flat Head - 1/4-20x 16 mm (Honey Bronze) will be 8302.42.3065, HTSUS, which provides for Base metal mountings, fittings and similar articles… Other mountings, fittings and similar articles, and parts thereof: Other, suitable for furniture: Of iron or steel, of aluminum or of zinc; Other. The duty rate will be 3.9 percent ad valorem. The applicable subheading for Item 4000197 8 Hex screws - Cap, PPH, Steel, Zinc Plated - 1/4-20 x 1 1/2" will be 7318.15.8045, HTSUS, which provides for Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: Threaded articles: Other screws and bolts, whether or not with their nuts or washers: Other: Having shanks or threads with a diameter of 6 mm or more… Other: Socket screws: Other. The general rate of duty will be 8.5% ad valorem. The applicable subheading for Item 4000207, 1 Screw - Sheet Metal, PFH, Steel, Zinc Plated - #10-12 x 3/4" will be 7318.14.1060, HTSUS, which provides for Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: Threaded articles: Self-tapping screws: Having shanks or threads with a diameter of less than 6 mm… Other. The general rate of duty will be 6.2% ad valorem. The applicable subheading for Item 5340005, 4 Pin and Cable - Quick Release Steel Hd/Ft board will be 7318.29.0000, HTSUS, which provides for Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: Non-threaded articles: Other. The rate of duty will be 2.8%. The applicable subheading for Item 4000036, 4 Insert - Plastic "IV" Socket and Item 4040025, 1 Clamp - Adjustable Nylon Cable will be 3926.90.9989, HTSUS, which provides for “Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Other: Other.” The general rate of duty is 5.3 percent ad valorem. The applicable subheading for the 4 mm hex wrench will be 8204.11.0060, HTSUS, which provides for Hand-operated spanners and wrenches (including torque meter wrenches but not including tap wrenches); Socket wrenches, with or without handles, drives and extensions; base metal parts thereof: hand-operated spanners and wrenches, and parts thereof: Nonadjustable, and parts thereof: Other (including parts). The general rate of duty will be 9% ad valorem. OPIOIDS 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 subheadings 8302.42.3065, 7318.15.8045, 7318.14.1060, 7318.29.0000, 3926.90.9989, or 8204.11.0060, HTSUS, listed above. Section 232 Steel Derivative products On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter 99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 percent upon the value of the steel content. At the time 

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 Jennifer Jameson at jennifer.d.jameson@cbp.dhs.gov. 
Sincerely,
 (for) James Forkan Acting Director National Commodity Specialist Division