Enameled cast iron dutch oven, 6 quart, with self-basting lid and loop handles

GRI Reasoning

GRI 1 — Heading Determination

Heading 7323 covers "Table, kitchen or other household articles and parts thereof, of iron or steel." A dutch oven is a kitchen/cooking article of cast iron, squarely within this heading. No other heading competes: heading 7321 covers stoves, ranges, and similar *appliances* — not cooking *vessels* — and is excluded.

GRI 6 — Subheading Selection

Within 7323, the structure is:

• 7323.91: Of cast iron, not enameled
• 7323.92: Of cast iron, enameled ← correct branch
• 7323.93: Of stainless steel
• 7323.94: Of iron (other than cast iron) or steel, enameled

The product is described as enameled cast iron, directing classification to 7323.92.00. Ruling H185697 (HQ, 2012) adjudicated this exact subheading split for cast iron cookware including dutch ovens, holding that a genuine enamel finish places goods in 7323.92 rather than 7323.91. Pre-seasoned oil-paint finishes were found NOT to be enamel; by contrast, a product described from the outset as "enameled cast iron" carries an enamel finish that satisfies 7323.92.

10-Digit Statistical Suffix

Under 7323.92.00, two suffixes exist:

• 7323.92.00.20: Bakeware (cookware NOT suitable for stove-top use)
• 7323.92.00.40: Other

A 6-quart dutch oven with a self-basting lid and loop handles is versatile stovetop and oven cookware — definitionally not bakeware. Suffix .40 applies.

Duty Rate

• General (Column 1): Free (per 7323.92.00 HTS row)
• Column 2 (China if not NTR): 35.5%
• Section 301 overlay: The HTS row for 7323.92.00 carries a footnote referencing 9903.88.15, which per the Chapter 99 overlay rows imposes "the duty provided in the applicable subheading + 7.5%" for Chinese-origin goods enumerated in U.S. Note 20(s). This is flagged as an additional-overlay to verify with a broker or ACE ruling; it is not an invented rate — it appears verbatim in the supplied 9903.88.15 row.

Effective duty estimate (if 9903.88.15 applies): Free + 7.5% = 7.5% ad valorem (Column 1 + Section 301 add-on).

Candidate Codes Rejected

| Code | Reason Rejected |

|---|---|

| 7323.91.50.40 | Cast iron NOT enameled — product IS enameled per description; H185697 confirms the distinction |

| 7323.99.9060 | Residual 'other' — only appropriate if cast iron or enamel character were disputed; no basis here |

| 7321.11.1000 | Cooking appliances (stoves/ranges), not cooking vessels; wrong heading |

Financial Exposure Estimate

• Unit value: $21.50 × 3,000 units = $64,500 annual import value
• Duty at 7.5% (Free base + 9903.88.15): ~$4,838/year
• If 9903.88.15 does not apply: $0 base duty (Free column)
• Broker should confirm current 9903.88.15 applicability and any active exclusions under 9903.88.39, 9903.88.42, 9903.88.44, etc.