Newly Released CBP HQ Rulings July 31
The Customs Rulings Online Search System (CROSS) was updated July 31 with the following headquarters rulings (ruling revocations and modifications will be detailed elsewhere in a separate article as they are announced in the Customs Bulletin):
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H320936: Revocation of HQ 953138; Modification of NY N284130; Tariff classification of reflective aluminum composite panels
| Ruling: The subject reflective aluminum composite panels with an aluminum component thickness exceeding 0.2 mm are classified in heading 7606 as “Aluminum plates, sheets and strip, of a thickness exceeding 0.2 mm.” The reflective aluminum composite panels with an aluminum component thickness not exceeding 0.2 mm are classified in heading 7607 as “Aluminum foil (whether or not printed, or backed with paper, paperboard, plastics or similar backing materials) of a thickness (excluding any backing) not exceeding 0.2 mm.”In order to provide duty rates, the items must be specifically described and identified. |
| Issue: Are the subject reflective aluminum composite panels properly classified in heading 7606, HTSUS, as aluminum sheets; heading 7607, HTSUS, as aluminum foil; or heading 7616, HTSUS, as other articles of aluminum? |
| Items: A-Look and A-Look EX. A-Look is a composite material made by laminating a polyethylene core between two sheets of aluminum alloy. The silver colored surface is electroplated with a layer of nickel and chromium, the bronze colored surface is electroplated with nickel alloy, and the gold colored surface is electroplated with brass. The back of A-Look is coated with an acrylic resin. A-Look EX is also a composite material made by laminating a polyethylene core between two sheets of aluminum alloy with a backing of fluoride resin. It is specially designed for use outdoors and in locations exposed to high humidity. Both articles are imported in standard sizes ranging from 2 feet square to 4 feet by 10 feet square, however they can be manufactured in any size. Both products' reflective exterior surface may be etched or inscribed with decorative patterns. Both can be bent and applied to curved surfaces, machined to different sizes and shapes, and mechanically worked. Both articles are used in ceilings, walls, columns, furniture, displays, and as trims and accents. |
| Reason: The aluminum component imparts the essential character of these articles. The reflective aluminum composite panels are classified based on the thickness of the aluminum component. Classification at the subheading depends on whether the aluminum composite panels are backed and whether they are rolled but not further worked. |
| Ruling Date: May 10, 2023 |