H355020

H355020 January 13, 2026 OT:RR:CTF:FTM H355020 BJK CATEGORY: Classification, Marking, and USMCA Eligibility TARIFF NO.: 3926.90.10 Mr. Charly Thibault OilCatch P.O. Box 356 Falher, Alberta T0H 1M0 Canada RE: Tariff Classification; Country of Origin Marking; USMCA Eligibility of OilCatch Product Dear Mr. Thibault: This letter is in response to your request submitted to U.S. Customs and Border Protection (“CBP”), dated October 6, 2025, for a binding ruling regarding the tariff classification under the Harmonized Tariff Schedule of the United States (“HTSUS”), the country of origin marking, and the eligibility for preferential tariff treatment under the United States Mexico Canada Agreement (“USMCA”) of an OilCatch product. Our response is based on the information provided in the initial ruling request as well as additional information furnished on December 17, 2025 via e-mail. FACTS: In the ruling request, the OilCatch product is described as “a hand tool used during oil filter changes to capture residual oil and prevent spills.” Based on photographs provided in connection with the ruling request, the OilCatch product resembles a bucket in varying sizes. The product is made via 3D printing using thermoplastic polyurethane (“TPU”) filament to create the main body. The TPU plastic main body is fastened with steel rivets to permanently tie the product together to create the finished OilCatch product. The product is available in four different sizes (small, medium, large, and extra-large) and can be purchased individually or as a bundle, for which one of each size is packaged together. All size configurations are composed of the same materials. The 3D printing, assembly operations combining the steel rivets to the TPU plastic main body, trimming to size, and packaging are conducted exclusively within Canada. The TPU filament that is used in the 3D printing of the product is purchased from a Canadian producer of the filament. The 3D printing is performed in Canada. The steel rivets added to the TPU main body in Canada are purchased from a Canadian producer. The finished product, or bundle, is placed inside cardboard boxes, palletized, and prepared for shipment, all within Canada. In the ruling request, the suggested tariff classification of the OilCatch product is subheading 3926.90.10, HTSUS, which provides for “Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Buckets and pails,” or alternatively, subheading 3926.90.99, HTSUS, which provides for “Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Other.” Additionally, confirmation is sought that the product is properly marked as “Made in Canada” pursuant to CBP regulations, 19 C.F.R. Part 134, and that the product is eligible for preferential tariff treatment under the USMCA. ISSUES: What is the tariff classification of the OilCatch product? What is the country of origin marking of the OilCatch product? Whether the OilCatch product is eligible for preferential tariff treatment under the USMCA. LAW AND ANALYSIS: Classification decisions under the HTSUS are made in accordance with the General Rules of Interpretation (GRI). GRI 1 provides that the classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may then be applied in order. GRI 2(b) states as follows: Any reference in a heading to a material or substance shall be taken to include a reference to mixtures or combinations of that material or substance with other materials or substances. Any reference to goods of a given material or substance shall be taken to include a reference to goods consisting wholly or partly of such material or substance. The classification of goods consisting of more than one material or substance shall be according to the principles of rule 3. GRI 3 states that: 2 When, by application of rule 2(b) or for any other reason, goods are, prima facie, classifiable under two or more headings, classification shall be effected as follows: (a) The heading which provides the most specific description shall be preferred to headings providing a more general description. However, when two or more headings each refer to part only of the materials or substances contained in mixed or composite goods . . . those headings are to be regarded as equally specific in relation to those goods, even if one of them gives a more complete or precise description of the goods. (b) Mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale, which cannot be classified by reference to 3(a), shall be classified as if they consisted of the material or component which gives them their essential character, insofar as this criterion is applicable. * * * The 2026 HTSUS provisions under consideration are as follows: 3926 Other articles of plastics and articles of other materials of headings 3901 to 3914: * * * 3926.90 Other: 3926.90.10 Buckets and pails * * * 3926.90.99 Other * * * 7318 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: 7318.23.00 Rivets 3 * * * The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the “official interpretation of the Harmonized System” at the international level. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (Aug. 23, 1989). While neither legally binding nor dispositive, the ENs “provide a commentary on the scope of each heading” of the HTSUS and are “generally indicative of [the] proper interpretation” of these headings. See id. The ENs for GRI 3(b) provide, in pertinent part: The factor which determines essential character will vary as between different kinds of goods. It may, for example, be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the goods. * * * CLASSIFICATION: The OilCatch product at issue is composed of TPU filament that is 3D printed into a TPU plastic main body, resembling the shape of a bucket, which is fastened with steel rivets for use in oil filter changes to capture residual oil and prevent spills. In applying the GRIs to determine the appropriate tariff classification, CBP notes that pursuant to GRI 1, there is no heading or subheading that accurately captures the OilCatch product as a plastic bucket with steel rivets for use in oil filter changes. Thus, tariff classification of the OilCatch product cannot be determined pursuant to GRI 1. In applying the GRIs in sequential order, GRI 2(a) relates to articles presented unassembled or disassembled. As the OilCatch product is imported in a finished condition, GRI 2(a) is not applicable in this case. As a result, GRI 2(b) is applied. GRI 2(b), in pertinent part, states that: “[t]he classification of goods consisting of more than one material or substance shall be according to the principles of rule 3.” CBP observes that the OilCatch product is composite good of both TPU plastic and steel rivets. As such, CBP applies GRI 3. As noted above, GRI 3(a) provides that tariff classification of a product consisting of two or more different materials should be determined based on the most specific description of the product over a more general description; however, when the headings only refer to a part of the product, those headings are “regarded as equally specific in relation to those goods.” Here, subheading 3926.90.10, HTSUS, refers to the plastic bucket and subheading 7318.23, HTSUS, refers to the steel rivets. Since both subheadings specifically reference only a part of the OilCat

Classification decisions under the HTSUS are made in accordance with the General Rules of Interpretation (GRI). GRI 1 provides that the classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may then be applied in order. GRI 2(b) states as follows: Any reference in a heading to a material or substance shall be taken to include a reference to mixtures or combinations of that material or substance with other materials or substances. Any reference to goods of a given material or substance shall be taken to include a reference to goods consisting wholly or partly of such material or substance. The classification of goods consisting of more than one material or substance shall be according to the principles of rule 3. GRI 3 states that: 2 

When, by application of rule 2(b) or for any other reason, goods are, prima facie, classifiable under two or more headings, classification shall be effected as follows: (a) The heading which provides the most specific description shall be preferred to headings providing a more general description. However, when two or more headings each refer to part only of the materials or substances contained in mixed or composite goods . . . those headings are to be regarded as equally specific in relation to those goods, even if one of them gives a more complete or precise description of the goods. (b) Mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale, which cannot be classified by reference to 3(a), shall be classified as if they consisted of the material or component which gives them their essential character, insofar as this criterion is applicable. * * * The 2026 HTSUS provisions under considerat