N364860

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364860 September 22, 2026 CLA-2-87:OT:RR:NC:N2:201 CATEGORY: Classification TARIFF NO.: 8716.90.5060 Mr. Tobias Andris Toby's Mechanical LLC 33217 Katy Lee Ln Magnolia, TX 77354 RE: The tariff classification of trailer walls from Italy. Dear Mr. Andris: In your letter dated September 4, 2026, you requested a tariff classification ruling. The items under consideration have been identified as Isolpack "Alfa 2", 40 mm, (Item PWPD40), which is a composite panel consisting of two outer facings of galvanized, pre-painted steel sheets, each approximately 0.5 mm thick, bonded to a rigid closed-cell polyurethane (PUR/PIR) foam insulating core approximately 39 mm thick; total panel thickness of 40 mm. Nominal panel width of approximately 1,000 mm; supplied in lengths of 2,333 mm and 2,032 mm. Approximate weight of 9.07 kg/m2, of which the steel facings are approximately 7.45 kg/m2 (about 82% by weight); the polyurethane core is the balance. You state that the panels are cut and fitted to form the insulated, temperature-controlled body of mobile food/concession trailers. Their principal function is thermal insulation. You claim that they are not imported or used as parts of buildings or for building/construction erection. In your request you suggest classification in various Harmonized Tariff Schedule (HTS) provisions. We shall address each in turn. First, you suggest classification in 3925.90 (builders' ware of plastics), reflecting the panel's principal insulating function. An examination of the Customs Ruling Online Search System ( CROSS) revealed rulings of similar merchandise classified in 7308 rather than 3925. HQ 083331 5/2/1989; N334347 8/4/2023; N359467 3/27/2026. Next, you suggest classification in HTSUS 7308.90, which provides for “structures and parts of structures of iron or steel”, based on the steel facing. Classification in Heading 7308 would not apply, as the panels are designed for use in trailers, which are excluded from the scope of "structures" under Heading 7308. Finally, you suggest classification in HTSUS 9406.90, which provides for “prefabricated buildings.” Classification in 9406 is precluded. The panels themselves are used for insulation. According to your request statement, "[T]hey are not imported or used as parts of buildings or for building/construction erection." They are not components making up a whole recognizable building. They are merely materials used in the construction of a building. The applicable subheading for the Isolpak “Alfa 2”, Item PWPD40, will be 8716.90.5060, HTSUS, which provides for “Trailers and semi-trailers; other vehicles, not mechanically propelled; and parts thereof: Parts: Other: Other.” The general rate of duty will be 3.1 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 the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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 Matthew Sullivan at matthew.sullivan@cbp.dhs.gov. Sincerely, (for) James P. Forkan 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 Matthew Sullivan at matthew.sullivan@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division