Folding Door Kits Packed Separately Still Get 'Finished Goods Kit' Exemption From Extrusions Duties
Folding door kits imported by Phoenix Folding Door Co. (PFDC) are “finished goods kits” exempt from antidumping and countervailing duties on aluminum extrusions from China (A-570-967/C-570-968), even though some components are packaged separately at the time of importation, the Commerce Department said in a recent scope ruling.
Sign up for a free preview to unlock the rest of this article
If your job depends on informed compliance, you need International Trade Today. Delivered every business day and available any time online, only International Trade Today helps you stay current on the increasingly complex international trade regulatory environment.
The folding door kits include extruded aluminum components as well as components of other materials, and they are ready for installation into residential and commercial buildings with no further manufacturing or fabrication. At importation, all components are packaged together except for the large door panels and door frames, which are packaged separately. They are, however, all listed together on the same CBP Form 7501 entry summary, and do not need to be rearranged and repackaged following importation before they are sent to purchasers.
Commerce has found that “merchandise imported in separate packaging may be considered a kit in certain circumstances, such as when the product contains large pieces, which ‘would make them difficult to contain in a single package,’” the agency said in the scope ruling. Here, Commerce found “the large size of the folding door kits components (e.g., the door panels and door frames) would make them difficult to contain in a single package with the much smaller components.”
Commerce also found that, despite the separate packaging, “the folding [door] kits are packaged to be sold as complete kits at the time of importation.” Though PFDC has not actually imported the folding door kits yet, the agency noted that “PFDC submitted packing lists, component lists, and photos of the packaging which demonstrated that the components of the folding doors kits are not rearranged after importation.” PFDC “has demonstrated through questionnaire responses, photographs, and exhibits its intended method of importation and storage,” Commerce said.
Email ITTNews@warren-news.com for a copy of this scope ruling.