Nov. 12 CBP Bulletin Proposes to Revoke, Modify Rulings on Steel, Brass Escutcheons
In the Nov. 12 issue of the CBP Customs Bulletin (Vol. 48, No. 45), CBP published notices that propose to modify or revoke rulings and similar treatment for the tariff classification of brass and steel shower escutcheons (here).
Comments on Proposals Due Dec. 12
CBP said consideration will be given to any written comments received by Dec. 12 before taking this action. In addition, any party who has received a ruling or decision on the merchandise that is subject to the proposed revocations, or any party involved with a substantially identical transaction, should advise CBP by the date that written comments on the proposed ruling are due. (An importer's failure to advise CBP of such rulings, decisions, or substantially identical transactions may raise issues of reasonable care on the part of the importer or its agents for importations subsequent to the effective date of the final decision in this notice.)
Proposals
CBP is proposing to revoke or modify the rulings below, and any rulings on these products that may exist but have not been specifically identified. CBP is also proposing to revoke or modify any treatment it has previously accorded to substantially identical transactions.
Brass Escutcheons
| Item: Chrome-plated brass escutcheon. The escutcheon is a trim component for bathtubs and showers that is used to hide the hole in the wall around a shower arm or bathtub spout, and to contribute to the bathroom’s décor. |
| Current: 8481.90.1000, 3% (Taps, cocks, valves and similar appliances … parts thereof: Parts: Of hand operated and check appliances: Of copper …) |
| Proposed: 7419.99.50, Free (Other articles of copper: Other: Other: Other: Other …) |
| Reason: The escutcheon is not a "part" and not classifiable elsewhere in the tariff schedule. Heading 7419, provides for other articles of copper and covers articles of copper which are not classified elsewhere in the tariff schedule. |
| Proposed for modification: NY NI86062 (2002), NY 803902 (1994) |
| Proposed new ruling: HQ H201157 |
Steel Shower Escutcheons
| Item: Chrome-plated steel escutcheon, also known as a shower arm flange. It is designed to cover the hole on the bathroom shower wall where the shower arm projects and contributes to the bathroom’s décor. |
| Current: 7324.90.0000, Free (Sanitary ware and parts thereof, of iron or steel, other, including parts.) |
| Proposed: 7326.90.85, 2.9% (Other articles of iron or steel: Other: Other: Other….) |
| Reason: A steel escutcheon is not a "part" and is of a "strictly decorative nature," so is not classifiable under heading 7324, said CBP. It should instead be classified under heading 7326, which covers articles of steel not classified elsewhere in the tariff schedule. |
| Proposed for revocation: NY L89621 (2006) |
| Proposed new ruling: HQ H201156 |