N354285

N354285 October 22, 2025 CLA-2-83:OT:RR:NC:N4:422 CATEGORY: Classification TARIFF NO.: 8305.90.6000; 9903.02.56 Mr. Carlos Llanos Crestview Partners LLC dba McIntire Business Products 128 Hall Street Suite K Concord, NH 03301 RE: The tariff classification of a wire spool and wire binding spines from South Korea Dear Mr. Llanos: In your letter dated September 27, 2025, you requested a tariff classification ruling. Product photos and website information were submitted for review. The merchandise under consideration is referred to as a “3:1 Pitch 1/4" White Wire-O Spool (90,000 Loops),” Item#91WM14SPLWHT, and “Black 3:1 Wire-O Twin-Loop Binding Spines (Box of 100),” Item#WIREOBINDINGBK31-GRP. The first item, the “3:1 Pitch 1/4" White Wire-O Spool (90,000 Loops),” Item#91WM14SPLWHT, is a finished steel product with polyethylene terephthalate (PET) coating. It is wound on a spool and is used on automatic wiring machines. The wire spool is used for wire binding to bind reports, calendars, notebooks, and presentations. It features 90,000 loops of wire binding. The wire diameter (thickness) varies in size: 1/4", 5/16", 3/8", 7/16", 1/2", 9/16", 5/8", 3/4", 7/8", 1", 1 1/8", and 1 1/4." The second item, the “Black 3:1 Wire-O Twin-Loop Binding Spines (Box of 100),” Item#WIREOBINDINGBK31-GRP, s a finished steel product with PET coating. It is cut into 11-inch pieces to wire bind loose-leaf reports, presentations, calendars, notebooks, and journals. The wire diameter (thickness) varies in size: 3/16", 1/4", 5/16", 3/8", 7/16", 1/2", and 9/16." In your request, you propose classification of the merchandise in subheading 8305.10.00, Harmonized Tariff Schedule of the United States (HTSUS), which provides for fittings for looseleaf binders or files. We disagree. The wire spool and wire binding spines are not of the same class or kind provided in subheading 8305.10.00, HTSUS. They are more appropriately classified under another subheading. The applicable subheading for the “3:1 Pitch 1/4" White Wire-O Spool (90,000 Loops),” Item#91WM14SPLWHT, and the “Black 3:1 Wire-O Twin-Loop Binding Spines (Box of 100),” Item#WIREOBINDINGBK31-GRP will be 8305.90.6000, HTSUS, which provides for “Fittings for looseleaf binders or files, letter clips, letter corners, paper clips, indexing tags and similar office articles, and parts thereof, of base metal; staples in strips (for example, for offices, upholstery, packaging), of base metal: Other, including parts: Other.” The general rate of duty will be 5.7 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 South Korea will be subject to an additional ad valorem rate of duty of 15 percent. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.56, in addition to subheading 8305.90.6000, 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 Dana L. Giammanco at dana.l.giammanco@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division 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 Dana L. Giammanco at dana.l.giammanco@cbp.dhs.gov. 
Sincerely,
 (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division