N359456

N359456 March 30, 2026 OT:RR:NC:N4:422 CATEGORY: Classification; Origin; Marking TARIFF NO.: 7323.99.7000; 9903.03.01 Ms. Misty Gibbins Pacific Customs Brokers Inc. 2150 Peace Portal Dr. Blaine, WA 98230 RE: The tariff classification, country of origin, and marking of a carbon steel pan set Dear Ms. Gibbins: In your letter dated February 19, 2026, you requested a binding ruling on the tariff classification, country of origin, and marking of carbon steel pan sets imported from Canada, on behalf of your client, Goso Cookware Inc. A detailed description of the manufacturing operation processes and photos were provided for our review. The sixth item will be addressed herein. The other five articles will be covered in New York Ruling N359002. The merchandise under consideration is described as an Outdoor Gourmet 2- pan Set (Item # EWP-OG2PS.) It consists of two pans, one handle, one leather protective pad, and a two-ounce tin of pan maintenance paste. The pan is made of 1008 raw carbon steel from the United States, and it is in a round shape. The handle is made of forged aluminum from Taiwan. The pan is available in 8-inch and 10-inch sizes. The Outdoor Gourmet 2- pan Set (Item # EWP-OG2PS) is designed to be used in the home for cooking. Classification: In your request, you indicated that carbon steel pan is from a U.S. manufacturer, stacked on pallets in your warehouse in Canada. The pan is packed in a plastic bag. The detachable handle is imported separately from Taiwan, packaged 24 individually boxed handles per case. The pan set is offered for sale containing Canadian-origin accessories (leather protective pads or pan maintenance paste). It will be imported in different groupings of articles not sold in retail stores, but sold directly to the consumer through the online. The General Rules of Interpretation (GRIs) set forth the legal framework in which merchandise is to be classified under the Harmonized Tariff Schedule of the United States Annotated (HTSUS). GRI 1 requires that classification be determined first according to the terms of the headings of the tariff and any relative section or chapter notes. Goods that cannot be classified in accordance with GRI 1 are to be classified in accordance with subsequent GRIs taken in order. GRI 3(b) covers goods put up in sets for retail sale. Such goods: (a) consist of at least two different articles that are classifiable in different headings, (b) consist of products put up together to meet a particular need or carry out a specific activity, and (c) are put up in a manner suitable for sale directly to users without repacking. The subject article, in the opinion of our office, meets the criteria for a set as the terms are defined. Having determined that the item constitutes a set for tariff classification purposes, we must decide the essential character. Essential character may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of the constituent material in relation to the use of the goods. The steel pan imparts the essential character of the set. Accordingly, the set is classified under heading 7323, Harmonized Tariff Schedule of the United States (HTSUS), which is the heading that applies to the carbon steel pan. The applicable subheading for the Outdoor Gourmet 2- pan Set (Item # EWP-OG2PS) will be 7323.99.7000, HTSUS, which provides for…kitchen…articles…of…steel…: other: other: not coated or plated with precious metal: other: cookingware. The general rate of duty will be 5.3 percent ad valorem. Effective February 24, 2026, a Presidential Proclamation implemented a temporary import surcharge. At this time, products of all countries will be subject to an additional ad valorem rate of duty of 10 percent. All imported merchandise must be reported with either the Chapter 99 provision under which the temporary import surcharge applies or one of the Chapter 99 provisions covering exceptions to the additional duties. For products covered by heading 9903.85.07 this additional duty applies to the non-aluminum content of the merchandise. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.03.01 , in addition to subheading 7323.99.7000, HTSUS, listed above. For further information on the additional duties listed above, please review the resources available on CBP’s Trade Remedy webpage available at the following link: https://www.cbp.gov/trade/programs-administration/trade-remedies. The 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. The tariffs and additional duties cited above are current as of this letter’s issuance. Please note that the HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by any Notes cited herein and any Chapter 99 subheadings. Country of Origin: For the pans, you stated that the raw material is sourced from Canada. The raw steel is smelted in Canada and shipped to the United States for the production processes. The pan production processes in United States are as follows: 1. Raw material preparation-round carbon steels blanks from the United States are cut to requested sizes and inspected for flaws. 2. Drawing-steel blanks are shaped into their desired form on a stamping press. 3. Trimming-frying pans are trimmed of excess material on the edges using a trimming die on the stamping press. 4. Deburring-pans are mounted on a lathe where the edge of the steel is deburred with a deburring tool. 5. Finishing-while pans are mounted on the lathe, the surface is polished to a consistent finish with a 3M Scotch-Brite pad. 6. Washing-pans are washed of machine/draw oil. 7. Oiling-a thin coating of food grade mineral oil is applied to all surfaces of the pan to prevent oxidizing in transport and storage. 8. Packaging-pans are placed in a disposable plastic bag to protect from dust and debris in transport and storage. 9. Palletizing-pans are placed on a pallet in singles layers with approximately 20 pans per layer separated by a piece of cardboard. They are shipped to the warehouse in Canada. For the detachable handle, you stated that the raw aluminum is sourced either in Australia or United Arab Emirates (UAE). They are shipped to Taiwan for the production processes. The handle production processes in Taiwan are as follows: 1. Raw Material Preparation-the raw aluminum extrusion is ordered from the supplier and prepared for manufacture. 2. Forging-the aluminum extrusion is heated to become malleable and then placed in a forge where the two different components that make up the handle body are forged into shape. 3. Flash Removal-any excess 'flash' (material) is removed from the forged handle components. 4. Tumbling-the handle components are tumbled to achieve a consistent surface texture. 5. Machining-slots and holes are machined into the raw components using 

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) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division