Forged aluminum nonstick frying pan, 10 inch, with ceramic coating and stainless handle
Country of origin for this scenario: China.
Recommended HTS code
7615.10.30.25
Other
MEDIUM confidence. Heading 7615 is clearly correct for a forged aluminum frying pan with a nonstick (ceramic) coating, supported by CBP rulings 082049 and 952099 classifying aluminum cookware under 7615.10. The product has a nonstick interior finish, placing it under 7615.10.30 (non-cast, nonstick) rather than 7615.10.20 (cast, nonstick). The pan is suitable for stovetop use, so it is 'other' not 'bakeware,' pointing to 7615.10.30.25. However, no ruling in the supplied evidence directly addresses a forged (vs. cast vs. foil/thin) aluminum frying pan at the 10-digit level, and confirmation that 'forged' maps to the 'other' (non-cast) breakout at 7615.10.30 rather than another subdivision should be verified with a licensed customs broker.
Classification analysis generated on July 17, 2026 from the current Harmonized Tariff Schedule and published CBP rulings, for the product description shown — our analysis, not legal advice.
The question to put to a licensed broker
Does a forged aluminum frying pan with a ceramic nonstick interior coating classify under 7615.10.30.25 (other, non-cast, nonstick, other cookware) rather than any other 10-digit subdivision of 7615.10, and is there any current USTR exclusion or product-specific treatment under 9903.88.15 applicable to this article?
How the classification was reached
GRI Reasoning
Step 1 — GRI 1: Heading Selection
The product is a forged aluminum frying pan with a ceramic nonstick coating and a stainless steel handle. The essential character is the forged aluminum body; the ceramic coating is a surface treatment and the stainless handle is an incidental component. Under GRI 1 and Note 2(b) to Section XV, surface treatments do not change classification of a base-metal article. Heading 7615 — *Table, kitchen or other household articles and parts thereof, of aluminum* — is the correct heading. Chapter 85 (heading 8516) is excluded because the pan contains no electric heating element.
CBP Ruling HQ 082049 (1989) classified an aluminum camping/cook kit under 7615.10.70 (the predecessor provision), confirming that aluminum cooking articles belong in heading 7615. CBP Ruling HQ 952099 (1993) similarly classified aluminum foil cooking containers (including frying pans, roasters, pie plates) under 7615.10.70, citing the Explanatory Note to heading 7323 which expressly lists *frying pans* as covered kitchen utensils.
Step 2 — GRI 6: Subheading Selection within 7615.10
The supplied HTS schedule for 7615.10 breaks down as follows for cooking and kitchen ware:
| Characteristic | Subheading |
|---|---|
| Nonstick / enameled / glazed + Cast | 7615.10.20 |
| Nonstick / enameled / glazed + Other (non-cast) | 7615.10.30 |
| Not nonstick / not enameled + Cast | 7615.10.50 |
| Not nonstick / not enameled + Other | 7615.10.71 |
This pan has a ceramic nonstick interior finish → falls under the "enameled or glazed or containing nonstick interior finishes" branch. It is forged (not cast) → falls under 7615.10.30 ("Other," i.e., non-cast).
Step 3 — 10-Digit Statistical Suffix under 7615.10.30
Within 7615.10.30:
- 7615.10.30.15 — Bakeware (cookware not suitable for stove top use)
- 7615.10.30.25 — Other
A frying pan is stovetop cookware, not bakeware → 7615.10.30.25.
Step 4 — Duty Rates
- General (MFN) rate: 3.1% (per 7615.10.30 row)
- Column 2 rate: 45.5% (per 7615.10.30 row)
- Special: Free for listed FTA partners (China is not among them)
- Section 301 overlay: 7615.10.30 carries a footnote referencing 9903.88.15. This is a Chapter 99 additional-duty flag for Chinese-origin goods that must be verified; it may impose an additional 7.5% or 25% Section 301 tariff on top of the 3.1% general rate. Broker/compliance team must confirm current applicability and rate under 9903.88.15.
Step 5 — Alternative Codes Eliminated
- 7615.10.20.25 (cast, nonstick, other): Eliminated — product is forged, not cast.
- 7615.10.71.55 (non-cast, no nonstick, other cookware): Eliminated — product has a nonstick ceramic coating.
- 8516.60.4000: Eliminated — product is non-electric.
Step 6 — Financial Exposure Estimate
- Unit value: $6.80; Annual units: 9,000 → Annual FOB value: ~$61,200
- MFN duty at 3.1%: ~$1,897/year
- If 9903.88.15 applies at +7.5%: additional ~$4,590/year → total ~$6,487/year
- If 9903.88.15 applies at +25%: additional ~$15,300/year → total ~$17,197/year
- Verify 9903.88.15 rate and any available exclusion before entry.
Cited CBP rulings
Every ruling below was fetched from CBP’s public CROSS database and verified to exist before this page was published. Links go to the official ruling text.
What it classified: Six-piece aluminum camping/cook kit (bowls, plates, carry bag) from China
Why it’s analogous: CBP confirmed aluminum cooking and eating articles are classifiable under heading 7615 (then subheading 7615.10.70) as table/kitchen household articles of aluminum; GRI 1 analysis applies directly to aluminum cookware.
What it classified: Aluminum foil containers (carry-out containers, pizza pans, tart pans, pot pie pans, pie plates, roasters) from Canada
Why it’s analogous: CBP held that aluminum cooking/kitchen articles including frying pans belong under heading 7615.10 citing EN 73.23 (which expressly lists frying pans); confirms that nonstick-coated or plain aluminum pans used in kitchen/cooking are covered by 7615.10 rather than heading 7612.
What the duty looks like
Duty math shown for illustrative declared values — $6.80 per unit at 9,000 units per year is our assumption for this explainer, not a measurement of anyone's imports. Your numbers will differ.
- Base duty rate (column 1, general)
- 3.1%
- Annual declared value at the illustrative numbers
- $61,200
- Base duty per year (illustrative)
- $1,897
Chapter-99 overlay headings flagged on this code
- 9903.88.15 — The duty provided in the applicable subheading + 7.5%. Except as provided in headings 9903.88.39, 9903.88.42, 9903.88.44, 9903.88.47, 9903.88.49, 9903.88.51, 9903.88.53, 9903.88.55, 9903.88.57, 9903.88.65, 9903.88.66, 9903.88.67, 9903.88.68, or 9903.88.69, articles the product of China, as provided for in U.S. note 20(r) to this subchapter and as provided for in the subheadings enumerated in U.S. note 20(s)
Overlay applicability depends on origin, entry date, and any active exclusions — verify at entry.
Alternatives considered
The full candidate set from the fetched tariff rows — including rows that would carry a higher duty. Shown so the reasoning is checkable, not to offer a rate menu.
| Code | Description | General rate | Note |
|---|---|---|---|
| 7615.10.20.25 | Cast | 3.1% | Would apply if the pan body were cast aluminum (not forged). Cast aluminum pans with nonstick finishes fall under 7615.10.20.25. The declared manufacturing method (forged) places this product under 7615.10.30.25 instead; however, if import documentation or CBP examination reveals the body is cast, this code should be used. |
| 7615.10.71.55 | Other | 3.1% | Applies to non-cast aluminum cookware WITHOUT a nonstick or enameled finish (rate also 3.1% general). Would be the correct code only if the ceramic coating is determined not to constitute a 'nonstick interior finish' within the meaning of the tariff schedule — an unlikely finding given the product description, but worth noting as a fallback. |
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