N365175

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 N365175 October 7, 2026 CLA-2-73:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7326.90.8688 Bret Holder Triad National Security, LLC 335 Central Park Square TA-00, Building 767 Los Alamos, NM 87544 RE: The tariff classification of hemispherical heads from France Dear Mr. Holder: In your letter dated August 3, 2026, you requested a tariff classification ruling. Informational material was submitted with your request. The products under consideration are hemispherical heads, which are steel articles designed to construct the shell of a containment vessel used for a Dual Axis Radiographic Hydrodynamic Test (DARHT). These heads are made of high strength steel alloys and forged in the shape of hollow hemispheres. In various configurations a circular opening can be cut at the top of the hemisphere and, additionally, there can be semicircular openings cut along the base depending on the vessel’s required design. Upon importation the heads are joined with other heads of similar size and configuration forming the shell of the vessel. In your submission, you suggest that the hemispherical heads are classified in subheading 7225.99.0090, Harmonized Tariff Schedule of the United States, (HTSUS), which provides for “Flat-rolled products of other alloy steel, of a width of 600 mm or more: Other: Other: Other: Other: Other: Other.” We disagree. The merchandise does not meet Chapter 72, Note 1 (k) and has assumed the character of articles or products other than that of flat-rolled products of other alloy steel. As an alternative, you also suggest that the hemispherical heads could be classified under subheading 9022.90.6000, HTSUS, as parts of an apparatus based on the use of X-rays. We disagree. Although the containment vessel is used in conjunction with an X-ray radiography system during hydrodynamic testing, it performs independent functions and serves a specific purpose separate from the X-ray apparatus. It is not a part of the X-ray radiographic apparatus. Therefore, the containment vessel is not classifiable under subheading 9022.90.6000, HTSUS, and, consequently, its hemispherical heads cannot be classified under that subheading either. Heading 7326, HTSUS, is a residual or basket provision which covers a wide range of iron or steel articles that are not more specifically provided for elsewhere in the HTSUS. The Explanatory Notes (ENs) to heading 7326 state that “This heading covers all iron or steel articles obtained by forging or punching, by cutting or stamping or by other processes such as folding, assembling, welding, turning, milling or perforating other than articles included in the preceding headings of this Chapter or covered by Note 1 to Section XV or included in Chapter 82 or 83 or more specifically covered elsewhere in the Nomenclature.” An article of iron or steel can be classified in heading 7326 if it is determined that the item is not more specifically provided for in any other heading of the tariff. The hemispherical heads are not specifically covered elsewhere in the tariff. Accordingly, they are classifiable in heading 7326, HTSUS. The applicable subheading for the hemispherical heads will be 7326.90.8688, HTSUS, which provides for “Other articles of iron or steel: Other: Other: Other: Other: Other.” The general rate of duty will be 2.9 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 Gay at matthew.gay@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 Gay at matthew.gay@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division