N347344

N347344 April 17, 2025 CLA-2-84:OT:RR:NC:N1:104 CATEGORY: Classification TARIFF NOS.: 8479.89.9599; 3926.90.9989; 9903.01.25 James Karnes Timing Guys, Inc. d/b/a Schill U.S. 7044 Winding Trail Brighton, MI 48116 RE: The tariff classification of cable reels and accessory covers from Germany Dear Mr. Karnes: In your letter dated April 1, 2025, you requested a tariff classification ruling. The products in question are several models of drum-shaped, hand crank cable reels (“cable reels” or “reels”), and plastic accessory and auxiliary winding drum covers (“accessory covers”) which will be imported either with the reels, or separately. The cable reels are used in the broadcast, military, electrical, medical, and various other industries to wind, organize, protect and transport cables, fiber optic cables, hoses, rope and any other flexible cable, tubes, or linear objects. The reels will be imported without cable or other winded material. The accessory covers are used with the cable reels to cover the drum’s core opening/axle and protect the cable/fiber terminations from contaminants, with certain styles providing some ancillary storage to the reel. The cable reels, models GT 450.MFK, IT 380.RM, HT 485-OFFEN, and SK 4813.RM, function by using a foldable crank handle on the outer flange to manually wind the fiber/cable onto the drum. This drum is supported by an axle protruding from the frame to allow rotation. A screw-style friction brake applies pressure to the back flange through the rear frame to control the rate of deployment to keep the fiber/cable from tangling while extending off/on the reel. This friction brake is also used to lock the drum from rotating during transport. The frame doubles as a lift handle for transporting the reel to multiple locations. The drum sizes for these four models range from 388mm to 460mm in diameter, and 137mm to 504mm in depth, with various cable capacities. The GT 450.MFK reel is made of plastic resins for both the drum and frame. It will be imported together with a round, flat plastic accessory cover (model MFK), which has a hinged, lockable latching door that protects the cable connectors inside the drum from contamination. The IT 380.RM reel’s drum is made of plastic, and the frame is made of steel tubing. It will be imported together with a plastic auxiliary winding cover (model RM) which is used for winding the tail end of cable on the front flange. The winding cover includes a Velcro keeper strap. The HT 485-OFFEN reel’s drum is made of sheet steel with a core of plastic, mounted on a frame of steel tubing. It will not be imported with an accessory cover. The SK 4813.RM reel is a professional stage cable drum for longer cable lengths. Its drum is made of sheet steel and a core of plastic. The SK 4813.RM reel is enclosed in a steel tube box frame which allows stacking of like reels for transport or storage to save space. It will be imported with the plastic “RM” auxiliary winding cover. Three reel covers, models- AD.KOMB SO cover (“SO”), KOMB.RM.310 (“RM”), and KOMB.310.MFK (“MK”), will also be imported separately. The SO is a round, flat blind cover plate used in conjunction with the cable drum to enclose the center core for protection of the axle. The RM and the MFK style covers are described above in connection with the IT 380.RM, GT 450.MFK, and SK 4813.RM. The applicable subheading for the cable reels, models GT 450.MFK, IT 380.RM, HT 485-OFFEN, and SK 4813.RM, will be 8479.89.9599, Harmonized Tariff Schedule of the United States (HTSUS), which provides for which provides for Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other: Other: Other.” The general rate of duty will be 2.5%. In your request, you suggest classification of separately imported accessory covers in subheading 8479.90.9596, HTSUS, covering other “parts” of machines and mechanical appliances of heading 8479.89. We disagree. The covers are marketed and catalogued by the company as “accessory covers” or auxiliary winding covers and are sold separately from the reel. While designed for use with the reels to enhance their utility, they are not required for the cable reels to perform their function of winding up cable and other materials. Rather, they are more akin to accessories. However, as heading 8479 does not include an accessory provision, the accessory covers, when imported without the reels, are separately classified elsewhere in the tariff. Accordingly, as these accessory covers, models AD.KOMB SO cover, KOMB.RM.310, and KOMB.310.MFK, would be considered articles of plastic, and as they are not more specifically provided for elsewhere, the applicable subheading 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 will be 5.3%. 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. Products of China, including Hong Kong and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other countries (including Germany) will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheadings 8479.89.9599 or 3926.90.9989, HTSUS, listed above. 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 the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. If 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 Arthur Purcell at arthur.purcell@cbp.dhs.gov. Sincerely, 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 the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. If 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 Arthur Purcell at arthur.purcell@cbp.dhs.gov. 
Sincerely,
 Steven A. Mack Director National Commodity Specialist Division