While Presidential Proclamations and the U.S. Trade Representative’s travels capture the headlines, U.S. Customs and Border Protection affects trade patterns and sourcing decisions through its multitude of rulings on the classification, valuation, marking, and origination of imports. CBP’s rulings can determine whether a steel product is subject to Section 232 tariffs or whether an import is a product of China for purposes of the Section 301 duties. Classification rulings are made by the National Commodity Specialist Division, and this process is usually initiated by a request from a private party.

During the past two months, CBP has issued rulings on the classification of stranded wire cable and strip staples from China and vineyard wire from Luxembourg. CBP issued a ruling that certain stranded wire rope or cable used in a window regulator pulley system is classified under a Tariff Code subject to a Section 301 duty of 25%. In the case of galvanized strip staples from China, CBP determined that they are not classified as a wire product subject to the 25% duty but under a different Tariff Code which carries a Section 301 duty of only 7.5%. Finally, CBP rejected the requestor’s claim that vineyard wire should be classified under a Tariff Code that is not covered by Section 232. Instead, CBP classified the wire so that it is subject to Section 232 coverage under the European Union’s Tariff Rate Quota (TRQ) agreement. Laboring out of the limelight, CBP’s specialists prepare rulings that can have a profound effect on the business plans and operations of U.S. importers and their customers.