What's the HS Code for "Safes"?

NY 807387 March 1, 1995 CLA-2-83:S:N:N3:113 807387 CATEGORY: Classification TARIFF NO.: 8303.00.0000 Mr. Octavio Saavedra Corrigan Dispatch Company Box 26457 1535 Goodyear, Suite A-8 El Paso, Tx 79936 RE: The tariff classification of armored safety boxes from Mexico Dear Mr. Saavedra: In your letter dated February 15, 1995, you requested a tariff classification ruling. The merchandise consists of the Models 610T-GY Personal File, H-260T-GY Cash Box, the H-300T-GY Security Chest and the H- 400T-GY King-sized Insulated Security Chest. These armored steel boxes have a textured grey enamel finish, and lock with a key. The applicable subheading for the steel boxes will be 8303.00.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for armored or reinforced safes, strong- boxes and doors, of base metal. The general rate of duty will be 5.3 percent ad valorem. This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177). A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction. Sincerely, Jean F. Maguire Area Director New York Seaport

NY 850672 March 27, 1990 CLA-2-83:S:N:N1:113 850672 CATEGORY: Classification TARIFF NO.: 8303.00.0000 Mr. John Williams President SeQwill Corporation 145 West Main Street Barrington, IL 60010 RE: The tariff classification of the CA 300 Safe-Key Box from Taiwan. Dear Mr. Williams: In your letter dated March 9, 1990 you requested a tariff classification ruling. A descriptive brochure of the CA 300 Safe-Key Box was submitted with your letter. The device is a small cast aluminum box resembling a padlock in appearance. It is an electronic lock box with its own unique set of 300 six- digit combinations. Combinations are entered on a membrane keypad and processed by a microcomputer-based system powered by a lithium battery. The Safe-Key Box is used by real estate agents. The shackle on the device secures it to a doorknob or other suitable fixture on the home and the proper keypad combination gives the real estate agent access to the house key secured within the box. The applicable subheading for the CA 300 Safe-Key Box will be 8303.00.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for armored or reinforced safes, strong-boxes and doors and safe deposit lockers for strong-rooms, cash or deed boxes and the like, and parts thereof, of base metal. The rate of duty will be 5.7 percent ad valorem. This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177). A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction. Sincerely, Jean F. Maguire Area Director New York Seaport

N319909 July 8, 2021 CLA-2-83:OT:RR:NC:N1:121 CATEGORY: Classification TARIFF NO.: 8303.00.0000; 9903.88.03 Silke Rees The Master Lock Company LLC 6744 S. Howell Ave. Oak Creek, WI 53154 RE: The tariff classification of parts of a safe from China and Taiwan Dear Ms. Rees: In your letter dated June 8, 2021 you requested a tariff classification ruling. The first item under consideration is described as a cast aluminum safe handle, SKU P65806, from China. It is an aluminum casting that is approximately 4.7 inches long, 2.5 inches tall, 1.5 inches wide, with a round base that is 1.5 inches in diameter. The handle is attached to zinc-plated steel spindle that is 3.82 inches long with a roll pin that is .375 inches long. You state you intend to import this item as an assembly. The safe handle assembly is inserted from the front of the safe door through the combination lock escutcheon and the clutching mechanism and then secured by an E-clip. When the lock releases the clutch, the user may turn the handle thereby retracting the bolts and opening the door. Any attempt to force the handle or pry it from the safe will cause the E-clip or the roll pin to fail, thereby disengaging the handle from the safe and hindering any unauthorized access. The base of the handle has small dimples that allow the handle to remain in a horizontal position. The second item under consideration is described as an extruded aluminum safe hinge, SKU P65875, from Taiwan. The imported component is an extruded aluminum hinge profile that is 6.16 inches long and drilled with unthreaded holes. Each safe uses a single hinge that will be surface mounted to the right side of the door using self-tapping screws inserted from the back of the door. The screws engage with the predrilled unthreaded holes. Two L-brackets with loops are welded to the right edge of the safe opening. Knurled hinge pins are forced through the holes of the bracket and into the safe hinge profile on either side. Once inserted the knurled pins create a secure connection that would require considerable force to be removed. The safe hinge assembly configuration also allows for there to be an uninterrupted gasket surrounding the door and the safe opening. The hinge profile will be imported without the pins, screws or brackets to connect the component to the door and the body of the safe. You state the safe handle and safe hinge are used exclusively in the SentrySafe fire and water protection safe line. Both the handle and hinge are integral, constituent, or component parts, without which the safe door could not be opened and closed. They are also designed to provide additional security features. The safe handle assembly includes a failsafe to hinder unauthorized access and is shaped and sized to interact with specific lock escutcheons. The safe hinge assembly is designed to support the weight of the heavy door while allowing for an uninterrupted gasket. In the case of a fire, the gasket is designed to melt, sealing the contents from danger. Consideration was given to classifying the safe handle and safe hinge under heading 8302, Harmonized Tariff Schedule of the United States (HTSUS), which provides for base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like. However, the subject handle and hinge are designed for reinforced security safes, which are not like any of the exemplars of 8302. Both the handle and hinge are integral working parts of the security safe and by design or function have no practical or commercial relationship to the exemplars of 8302. Accordingly, we find that the subject handle and hinge are not described in heading 8302. Chapter 83, Note 1 states, “For the purposes of this chapter, parts of base metal are to be classified with their parent articles.” As the subject safe handle and safe hinge are parts of safes of heading 8303, they will be classified with safes of heading 8303. The applicable subheading for cast aluminum safe handle, SKU P65806, and the extruded aluminum safe hinge, SKU P65875, will be 8303.00.0000, HTSUS, which provides for Armored or reinforced safes, strong-boxes and doors and safe deposit lockers for strong-rooms, cash or deed boxes and the like, and parts thereof, of base metal. The rate of duty will be 3.8 percent ad valorem. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8303.00.0000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8303.00.0000, HTSUS, listed above. The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively. 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/current. This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Jennifer Jameson at jennifer.d.jameson@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division

N307754 December 17, 2019 CLA-2-83:OT:RR:NC:N1:121 CATEGORY: Classification TARIFF NO.: 8303.00.0000, 9903.88.03 Christopher Vliet Diebold Nixdorf Incorporated 5995 Mayfair Road North Canton, OH 44720 RE: The classification of a steel metal safe and enclosure from China Dear Mr. Vliet: In your letter dated November 19, 2019 you requested a classification ruling. The articles under consideration are identified as “Enclosure, Safe UL, 7790” and “Enclosure, Safe CEN L, 7790.” They are for use in an Automated Teller Machine (ATM). The articles are comprised of two components: a large 5-sided steel frame, and a safe without a locking mechanism. The steel frame includes specific cutouts and fastening locations. The safe is anchored to the floor inside the steel frame. The safe is constructed of 13 mm high tensile steel plate and an additional layer of stainless steel on the door and top plate, and is made to ASTM A656 specifications or equivalent. The safe is manufactured to either UL or CEN L standards for ATM safes. The steel frame and safe are painted, two foam panels are added and then the articles are exported to the United States as the “Enclosure, Safe”. After importation, the ATM electronic equipment is placed above the safe inside the steel frame/enclosure. The wiring is then completed and outer panels are attached. You state the “Enclosure, Safe” is designed for a specific ATM model and provides, “much, if not nearly all the physical security involved in the ATM from weather, theft, and similar physical factors.” In your request, you suggest the “Enclosure, Safe” is properly classified under subheading 8473.40.8600, Harmonized Tariff Schedule of the United States (HTSUS), as a part or accessory to a currency or coin handling machine, and cite Note 2 to Section XVI as your reasoning. We disagree. Note 2 to Section 16 is first subject to Note 1, which excludes articles of Chapters 82 or 83 via Note 1(k). As the ATM Safe is prima facie classifiable under heading 8303, classification under subheading 8473.30.8600, HTSUS, is precluded. The applicable subheading for the “Enclosure, Safe UL, 7790” and the “Enclosure, Safe CEN L, 7790.” will be 8303.00.0000, HTSUS, which provides for Armored or reinforced safes, strong-boxes and doors and safe deposit lockers for strong-rooms, cash or deed boxes and the like, and parts thereof, of base metal. The rate of duty will be 3.8 percent ad valorem. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8303.00.0000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8303.00.0000, HTSUS, listed above.   The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively. 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 on World Wide Web at https://hts.usitc.gov/current. This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Jennifer Jameson at jennifer.d.jameson@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division

N025659 April 17, 2008 CLA-2-83:OT:RR:E:NC:N1:121 CATEGORY: Classification TARIFF NO.: 8303.00.0000 Mr. Richard Nguyen VMR Capital Group, LLC 2 Gold Street, Suite 903 New York, NY 10038 RE: The tariff classification and country of origin marking of a safe from China Dear Mr. Nguyen: In your letter dated April 3, 2008, you requested a tariff classification ruling. The sample which you submitted is being returned as requested. The merchandise under consideration is a steel lock box, model number PBS-001, made for storing firearms and valuables. The body of the box is made of heavy-duty 9 gauge steel (3 mm thick) with a 4 mm thick lid, which provides a strong, tamper-proof box. It measures 13.98 inches long by 10.24 inches wide by 4.73 inches high and weighs 22 lbs. The locking mechanism is a battery operated biometric fingerprint recognition device. It also comes with two mechanical keys that unlock a keyhole, which is located underneath the battery. The keyhole has an antidrilling washer that spins if a drill is used in a break-in attempt. Four pilot holes in the base panel allow the box to be mounted inside a drawer, to a wall or onto any flat surface. The applicable subheading for the safe will be 8303.00.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for armored or reinforced safes, strong-boxes and doors and safe deposit lockers for strong-rooms, cash or deed boxes and the like, and parts thereof, of base metal. The rate of duty will be 3.8 percent ad valorem. 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 on World Wide Web at http://www.usitc.gov/tata/hts/. You have also requested a ruling on whether the proposed method of marking the container in which the safe is imported with the country of origin in lieu of marking the article itself is an acceptable country of origin marking for the imported safe. A marked sample container was not submitted with your letter for review, however, you have submitted pictures of the proposed retail packaging. The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article. Part 134, Customs Regulations (19 CFR Part 134), implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.41(b), Customs Regulations (19 CFR 134.41(b)), mandates that the ultimate purchaser in the U.S. must be able to find the marking easily and read it without strain. Section 134.1(d), defines the ultimate purchaser as generally the last person in the U.S. who will receive the article in the form in which it was imported. If an imported article is to be sold at retail in its imported form, the purchaser at retail is the ultimate purchaser. In this case, the ultimate purchaser of the safe is the consumer who purchases the product at retail. An article is excepted from marking under 19 U.S.C. 1304 (a)(3)(D) and section 134.32(d), Customs Regulations (19 CFR 134.32(d)), if the marking of a container of such article will reasonably indicate the origin of such article. Accordingly, if Customs is satisfied that the article will remain in its container until it reaches the ultimate purchaser and if the ultimate purchaser can tell the country of origin of the safe by viewing the container in which it is packaged, the individual safe would be excepted from marking under 19 U.S.C. 1304 (a)(3)(D) and 19 CFR 134.32(d). Accordingly, marking the container in which the safe is imported and sold to the ultimate purchaser in lieu of marking the article itself is an acceptable country of origin marking for the imported safe provided the port director is satisfied that the article will remain in the marked container until it reaches the ultimate purchaser. This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Barbara Kaiser at 646-733-3024. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division

N036246 September 8, 2008 CLA-2-83:OT:RR:NC:N1:121 CATEGORY: Classification TARIFF NO.: 8303.00.0000; 9802.00.80 Mr. Dennis L. Sanner SinoRegent Group, Ltd. New Product Development 595 Holliday Lane Indianapolis, IN 46260-3516 RE: The tariff classification of a safe from China Dear Mr. Sanner: In your letter dated August 18, 2008, you requested a tariff classification ruling. The merchandise under consideration is a safe weighing 540 pounds (300 pounds is comprised of steel) that is imported unassembled in four cartons. It measures approximately 60 inches tall by 30 inches wide by 26.4 inches deep when fully assembled. Each of its six exterior panels measures 3 mm thick. The door measures 5 mm thick and has five 1-inch diameter locking bolts that extend and retract by turning an exterior 3-spoke handle. The door frame is faced with a special tape that swells when exposed to high heat to prevent flames entering any gaps around the door. The interior walls and ceiling are made of fabric-covered, 12 mm thick gypsum board faced with paper on two sides. The interior side walls are also faced with 3 mm wood panels that are cemented to the gypsum board. The tightly fit gypsum board and fire resistant tape around the door provide a fire rating of 1263°F (685°C) for 30 minutes. An anti-drill plate is welded to the interior of the door to armor the lock against entry via drilling. A spring-loaded relocker bolt is built into the door locking mechanism to prevent entry if an attempt is made to force the lock mount off the door. Forcing the lock by leveraging the rotating 3-spoke handle is prevented by an axle designed to shear if over-burdened. The safe is accessed via a U.S. made electronic numeric keypad, which activates a U.S. made electronic lock. According to your letter, the electronic keypads and locks are made in the U.S. The importer will ship them to China where the factory will bolt them, unaltered, into the steel safes. The Chinese factory will mount the keypad and lock to the door; then the keypad connector will be inserted into the bottom of the lock and tested for performance. No physical or functional change will occur to the keypad or lock in China. The applicable subheading for the safe will be 8303.00.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for armored or reinforced safes, strong-boxes and doors and safe deposit lockers for strong-rooms, cash or deed boxes and the like, and parts thereof, of base metal. The rate of duty will be 3.8 percent ad valorem. You ask whether the safe will be eligible for a partial duty exemption for the U.S. made keypads and locks. Subheading 9802.00.80, HTSUS, provides for a partial duty exemption for articles assembled abroad in whole or in part of fabricated components, the product of the U.S., which (a) were exported in condition ready for assembly without further fabrication, (b) have not lost their physical identity in such articles by change in form, shape or otherwise, and (c) have not been advanced in value or improved in condition abroad except by being assembled and except by operations incidental to the assembly process such as cleaning, lubricating and painting. All three requirements of subheading 9802.00.80, HTSUS, must be satisfied before a component is eligible to receive a duty allowance. An article entered under this tariff provision is subject to duty upon the full cost or value of the imported assembled article, less the cost or value of the U.S. components assembled therein, upon compliance with the documentary requirements of section 10.24, Customs Regulations (19 CFR 10.24).The assembly you described meets the three criteria listed above. From the information you provided, the U.S. keypad and lock were exported in condition ready for assembly without further fabrication, they have not lost their physical identity and were not advanced in value or improved in condition abroad except by being assembled into the safe. Therefore, the safe is eligible for a partial duty exemption under subheading 9802.00.8068, HTSUS, for the cost or value of the U.S. components identified above upon compliance with 19 CFR 10.24. 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 on World Wide Web at http://www.usitc.gov/tata/hts/. This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Barbara Kaiser at (646) 733-3024. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division

HQ H328086 March 6, 2023 OT:RR:CTF:CPMMA H328086 DAC CATEGORY:  Classification TARIFF NO.:  8303.00.00 Center Director Machinery Center of Excellence & Expertise 109 Shiloh Drive, Suite 300 Laredo, TX 78045 Attn: Jeremy Olson, Supervisory Import Specialist RE: Internal Advice; Classification of Hornady Manufacturing Company’s Titan metal gun vaults Dear Center Director: This is in response to your request for internal advice, dated December 22, 2021, regarding the tariff classification under the Harmonized Tariff Schedule of the United States (“HTSUS”) of a Hornady Manufacturing Company’s (“Hornady”) imported metal gun vault, identified as the Titan safe gun vault. The importer of the subject merchandise, Hornady, through their freight forwarder and customs broker, Total Logistics Resource, Inc. (“TLR”), alleges that the merchandise is classifiable under subheading 9403.20.0050, HTSUSA (“Annotated”), as “[o]ther furniture and parts thereof: Other metal furniture: Household: Other: Other.” FACTS: The subject merchandise is imported into the United States primarily through the Port of Seattle, Washington. Hornady requested a classification ruling from the from the Port of Minneapolis concerning its importations of the subject metal gun vaults. The Port of Minneapolis forwarded the submission as an internal advice request to CBP Headquarters, pursuant to 19 CFR § 177.11. According to Hornady, the Titan safe metal gun vault is used primarily for firearms storage, and also provides a variety of secure storage functions for other valuable articles. According to documentation submitted with Hornady’s request, the metal gun vault has exterior dimensions of 59" H x 22" W x 17.5" D (including an additional 3" for the handle), has interior dimensions of 55.125" H x 17" W x 14.5" D, and weighs 400 pounds. Hornady’s documentation states that the merchandise is constructed of “[American Iron and Steel Institute] AISI 1018 steel.” The metal gun vault also consists of eight locking bolts, has a storage capacity of 12 or more long guns, and a SecuRAM™ lock mechanism, which is a UL-listed digital lock with an EMP-proof mechanical key backup. Images of Titan safe metal gun vault provided by Hornady ISSUE:  Whether the Titan metal gun vault is classified under heading 8303, HTSUS, as “armored or reinforced safes, strong-boxes and doors and safe deposit lockers for strong-rooms, cash or deed boxes and the like, and parts thereof, of base metal,” or under heading 9403, HTSUS, as “other furniture and parts thereof.” LAW AND ANALYSIS: Classification under the HTSUS is made in accordance with the General Rules of Interpretation (GRI's). “GRI 1 dictates that classification shall be determined according to the terms of the headings and any relative section or chapter notes.” Amcor Flexibles Singen GmbH v. United States, 425 F. Supp. 3d 1287, 1298 (C.I.T. 2020). In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRI’s 2 through 6 may then be applied in order. The instant determination is made pursuant to GRI 1 and 6. GRI 6 provides that for legal purposes, the classification of goods in the subheadings of a heading shall be determined according to the terms of those subheadings and any related Subheading Notes and, mutatis mutandis, to the above Rules, on the understanding that only subheadings at the same level are comparable. For the purposes of this Rule the relative Section and Chapter Notes also apply unless the context otherwise requires. The HTSUS provisions under consideration are as follows: 8303.00.00 Armored or reinforced safes, strong-boxes and doors and safe deposit lockers for strong-rooms, cash or deed boxes and the like, and parts thereof, of base metal * * * * 9403 Other furniture and parts thereof: 9403.20.00 Other metal furniture Household: Other: 9403.20.0050 Other * * * * Note 1(k) to Section XV of the HTSUS provides, in pertinent part, as follows: 1.- This Section does not cover: … k) Articles of chapter 94 (for example, furniture, mattress supports, luminaires and lighting fittings, illuminated signs, prefabricated buildings); Note 1(d) to Chapter 94 provides, in pertinent part, as follows: This chapter does not cover: … (d) Parts of general use as defined in note 2 to section XV, of base metal (section XV), or similar goods of plastics (chapter 39), or safes of heading 8303. (Bold emphasis added.) The Explanatory Notes (“ENs”) to the Harmonized Commodity Description and Coding System represent the official interpretation of the tariff at the international level. While neither legally binding nor dispositive, the ENs provide a commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of these headings at the international level. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989).   EN 83.03 states, in pertinent part: This heading covers containers and strong-room doors designed for securing valuables, jewels, documents, etc., against theft and fire. Safes and strong-boxes of this heading are steel containers of which the walls are armoured (i.e., made of high-strength alloy steel) or of sheet steel reinforced with, for example, reinforced concrete. They are used in banks, offices, hotels, etc. They are fitted with very secure locks and often with air-tight doors and double walls, the intervening space usually being filled with heat resistant materials. The heading includes strong-room doors (whether or not with door frames) and safe deposit lockers for strong-rooms as used in banks, safe deposits, factories, etc., where larger storage space is required. … The heading Does not cover: … (b) Containers specially designed to resist fire, impact and crushing and whose walls in particular do not offer any serious resistance to attempts at breaking them open by drilling or cutting (heading 9403). Heading 9403, HTSUS, is subject to note 1(d) to chapter 94, which provides that Chapter 94 does not cover “[p]arts of general use as defined in note 2 to section XV, of base metal (section XV), or similar goods of plastics (chapter 39), or safes of heading 8303.” (Bold emphasis added.) The ENs for heading 8303 state, “Safes and strong-boxes of this heading are steel containers of which the walls are armoured (i.e., made of high-strength alloy steel)[.]” Additional U.S. Note 1(a) to Chapter 72, HTSUS, defines high strength steel as “Flat-rolled products of a thickness of less than 3 mm and having a minimum yield point of 275 [MegaPascals] MPa or of a thickness of 3 mm or more and having a minimum yield point of 355 MPa.” Additionally, American Iron and Steel Institute (AISI) describes 1018 steel as “a high-manganese carbon alloy” that “offers a good balance of toughness, strength and ductility.” The tensile strength, yield of AISI 1018 steel is 370 Mpa. See https://www.tsamfg.com/1018/#:~:text=AISI%201018%20is%20a%20high,best%20steel %20for%20carburized%20parts (last visited March 6, 2023). The Titan Metal Gun Safe features eight locking bolts and an interlocking door that prevents its removal, has an electronic locking system, and is protected by a casehardened anti-drill plate. The door is constructed of 6-gauge (5-millimeter (mm)) steel plate. The external walls, top and bottom are each constructed of two layers of 1.78 mm cold rolled steel, for a total thickness of 3.6 mm. Considering that the steel in the door is 5 mm thick; the walls, top and bottom are each made of two layers of steel that are each 1.78 mm thick; and that the steel has a yield point of 370 MPa, we find that steel meets the definition of high-strength alloy steel as provided in Additional U.S. Note 1(a) to Chapter 72, HTSUS. Thus, this product is considered armoured as specified by EN to heading 8303. Moreover, the gun vault by composition and construction is designed to provide serious resistance to attempts to being broken open by drilling or cutting. Finally, we note that the Titan Metal Gun Safe is designed to protect valuables against both fire and theft as specified in EN to heading 8303. Based upon the specifications, drawings, and images submitted, and the cited notes to Chapters 83 and 94, HTSUS, CBP finds that the Titan safe metal gun vault is specifically excluded from Chapter 94, HTSUS, and is properly classified under subheading 8303.00.00, HTSUS, which provides for “armored or reinforced safes, strong-boxes . . . and the like . . . of base metal.” This determination comports with several prior rulings: New York Ruling Letter (“NY”) 807387, dated March 1, 1995; NY N307754, dated December 17, 2019; NY 850672, dated March 27, 1990; and NY N036246, dated September 8, 2008. HOLDING: By application of GRIs 1 and 6, the Hornady Titan safe metal gun vault is classified under subheading 8303.00.00, HTSUS, which provides for “Armored or reinforced safes, strong-boxes and doors and safe deposit lockers for strong-rooms, cash or deed boxes and the like, and parts thereof, of base metal.” The 2023 column one, general rate of duty is 3.8% ad valorem. Duty rates are provided for the internal advice applicant’s convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided online at https://hts.usitc.gov/current. You are to mail this decision to the requestor no later than 60 days from the date of the decision. At that time, the Office of Trade, Regulations and Rulings will make the decision available to CBP personnel and to the public on the Customs Rulings Online Search System (“CROSS”), at https://rulings.cbp.gov/, and other methods of public distribution. Sincerely, Yuliya A. Gulis, Director Commercial and Trade Facilitation Division