In the Nov. 8, 2023, Customs Bulletin and Decisions, U.S. Customs and Border Protection is reclassifying the following products, effective with respect to goods entered or withdrawn from warehouse for consumption on or after Jan. 7, 2024.

For more information on how to seek or utilize classification and other rulings, please contact attorney Deb Stern at (305) 894-1007 or via email

Temporary Railings

CBP is reclassifying a strap rail tensioning system as a mechanical appliance with individual functions under HTSUS 8479.89.95 (2.5 percent duty) rather than as a winch under HTSUS 8425.39.0100 (duty-free). Ruling HQ H323869 will modify ruling NY N246928 to reflect this change.

The product at issue uses web strapping as a temporary railing to prevent workers and objects at construction sites from falling. This system uses a ratchet mechanism to tension the strapping to support the weight of a person or object.

CBP finds that the ratchet mechanism imparts the essential character of this system because it tensions the temporary railing. CBP further states that this mechanism is not a winch because it is not an independently-housed device that consists of a drum or cylinder turned by a crank or motor.

Steel Wire Cartridges

CBP is reclassifying steel wire cartridges as tool parts under HTSUS 8467.99.01 (duty-free) rather than as tools under HTSUS 8467.29.0090 (duty-free). Ruling HQ H330409 will modify ruling HQ H300804 to reflect this change.

The products at issue are steel tie wire cartridges consisting of spools of black annealed wire or polyester coated wire wrapped around black polypropylene cores. The cartridges do not resemble the typical packaging associated with wire products but instead have a sprocket-like appearance and are specially molded into a unique design that allows them to properly fit inside the designated tool. That tool is a battery-powered handheld power tool that incorporates a self-contained direct current motor and is used to tie and secure concrete rebar by holding the crossed reinforcing bars and feeding, winding, cutting, and tying the steel tie wire in one action.

CBP states that the cartridges meet the definition of “parts” because they are integral to, and dedicated solely for use with, the specified tool. Specifically, they are sold with steel tie wire inside, remain with the steel tie wire throughout its use by the tool, are the standard device for providing steel tie wire to the tool, and are not designed for reuse.

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