N357709

N357709 January 29, 2026 CLA-2-80:OT:RR:NC:N1:164 CATEGORY: Classification TARIFF NO.: 8007.00.3200 Jamie Thomas Harimatec 1965 Evergreen Blvd., St. 400 Duluth, GA 30096 RE: The tariff classification of tin-lead solder powder from France Dear Jamie Thomas: In your letter dated January 12, 2026, you requested a tariff classification ruling. Technical information was submitted with your request. The item under consideration is tin-lead solder powder (“Sn63Pb37”) which will be mixed with other ingredients to make solder paste after importation. Based on the submitted documentation, the powder is approximately 63 percent tin and approximately 37 percent lead. As indicated on the submitted certificate of analysis, 100 percent of the powder by weight is less than or equal to 50 micrometers in particle size. At importation, the solder powder will be packaged in a heat-sealing aluminum foil bag and labeled. You propose that the powder is classified in subheading 8001.20.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Unwrought tin: Tin alloys: Containing, by weight, more than 25 percent of lead.” We disagree. Classification under the HTSUS is in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods will 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 will then be applied in order. The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official interpretation of the HTSUS. While not 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 T.D. 89-80, 54 Fed. Reg. 35127 (August 23, 1989). The ENs to heading 8001 state “This heading covers unwrought tin in blocks, ingots, pigs, slabs, bars, sticks or similar forms, and fragments, granules and similar products, of tin…” In addition, the ENs to heading 8001 specify that “This heading excludes tin powders and flakes (heading 8007).” As a result, the powder at issue is not classified as unwrought tin. Section XV Note 8(b) defines powders as “Products of which 90% or more by weight passes through a sieve having a mesh aperture of 1 mm.” As described, 100 percent of the product by weight is less than or equal to 50 micrometers in particle size. Consequently, the subject powder meets the definition of powder outlined in Section XV. According to EN (A)(4) to Section XV, “The classification of mixtures of metal powders which have not been sintered, is however, governed by Note 7 to this Section.” Section XV Note 7 states that “…articles of base metal…containing two or more base metals are to be treated as articles of the base metal predominating by weight over each of the other materials.” As you specified, the solder powder is 63 percent tin by weight. The applicable subheading for the tin-lead solder powder will be 8007.00.3200, HTSUS, which provides for “Other articles of tin: Powders and flakes.” The general rate of duty will be 2.8 percent ad valorem. 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 Frequently Asked Questions on the Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ. 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 (C.F.R.), 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 C.F.R. 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 Paul Taylor at paul.m.taylor@cbp.dhs.gov. Sincerely, (for) Denise Faingar 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 (C.F.R.), 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 C.F.R. 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 Paul Taylor at paul.m.taylor@cbp.dhs.gov. 
Sincerely,
 (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division