Home / Blog / The 15 Per Cent Aluminium Test Behind an RFID Antenna’s US
Export 📅 October 4, 2026 ⏱ 13 min read

The 15 Per Cent Aluminium Test Behind an RFID Antenna’s US Customs Bill

A panel RFID antenna on a bench scale next to a US customs entry summary showing HTSUS 8517.71.00 and a Chapter 99 heading

A dock-door RFID portal lands on a United States entry summary as several lines rather than one: reader lines, antenna lines, cable, mounting hardware. Priced EXW the system is a single figure. Landed into the United States it stops being a single figure, because the antenna lines and the reader lines are assessed under different Chapter 99 measures — and the antenna measure turns on a weight fraction rather than on value.

That fraction is 15 per cent. Below it, an antenna is one thing at the border. At or above it, it is another, and the additional duty is assessed on the full customs value of the antenna rather than on the aluminium inside it. What follows reads the test off the tariff schedule, works one real antenna both ways, and gives you the question to put to any supplier in writing. Chapter 99 moves, so every figure here carries the date it was read — 3 October 2026, against HTSUS Revision 20 (2026) and the CBP guidance messages listed at the foot of this page — and the live note governs on the day you enter.

The cliff in one paragraph

An RFID antenna presented on its own is classified in HTSUS 8517.71.00, which the schedule describes as “Aerials and aerial reflectors of all kinds; parts suitable for use therewith”. Read off the Chapter 85 line in Revision 20 (2026), the Column 1 General rate is Free and the Column 2 rate is 35 per cent. CBP applied that exact subheading, and recorded the general rate as Free, in New York ruling N345860 of 19 February 2025 on a waveguide horn antenna imported from China.

That is where most landed-cost calculators stop. The schedule carries on. 8517.71.00 also appears in U.S. note 16(c)(vi) to subchapter III of chapter 99, a list headed “Derivative aluminum articles”. Articles on those lists pick up an additional Chapter 99 duty which, in the words of note 16(c), applies “to the full customs value” of the article — the whole invoice value of the line, not the value of the metal in it — and which engages once the applicable metal reaches 15 per cent of the weight of the imported article.

Below that line the antenna is reported under 9903.82.03, whose rate column reads “No change”. At or above it, an antenna built from ordinary commercial aluminium, outside the United Kingdom and United States metal-origin routes, falls to 9903.82.09: the duty provided in the applicable subheading plus 25 per cent. The 50 per cent heading that gets quoted in trade write-ups, 9903.82.02, reaches subdivisions (c)(i) to (c)(v) of note 16 — the chapter 72, 73, 74 and 76 metal articles. For an antenna the operative heading is 9903.82.09 at 25 per cent, which is half the exposure a 50 per cent assumption would put into a quote.

Chapter 99 headingWhat the schedule says it reachesAdditional rate on full customs value
9903.82.02Articles of aluminium, steel and copper in note 16(c)(i)–(v)+50%
9903.82.03Except for articles classifiable in chapters 72, 73, 74 or 76, articles where the weight of the applicable metal is less than 15 per cent of the weight of the imported article, as provided for in note 16(c)No change
9903.82.05Derivative aluminium or steel articles the product of the United Kingdom, in (c)(vi)–(vii) and (d) — note 16(d) carries a 95 per cent UK smelt-or-most-recently-cast test+15%
9903.82.06Except as provided in 9903.82.15 and 9903.85.68, articles of copper and derivative aluminium and steel articles in (c)(ii), (iv), (vi)–(viii), (xi) and (e) — note 16(e) carries an 85 per cent US smelt-and-cast test+10%
9903.82.09Except as provided in 9903.82.16, 9903.82.20–9903.82.26 and 9903.85.68, articles of copper and derivative aluminium and steel articles in (c)(vi)–(viii) and (xi) — the residual route for imported metal+25%

Note 16(a) makes these headings mutually exclusive: an imported article “will be subject to no more than one of these headings”. So the whole question for an antenna line is which single heading it lands in, and that is settled by a number on a scale.

The second edge runs the other way

The Section 301 forced-labour action announced by USTR on 23 July 2026 and set out in CBP’s CSMS #69326983, effective 12:01 a.m. eastern standard time on 24 July 2026, places an additional 10 per cent on articles the product of India under heading 9903.05.44, “Except for products described in headings 9903.05.85–9903.05.92”. One of those exceptions, 9903.05.90, carves out derivative aluminium articles, and U.S. note 52(f)(1) defines the carve-out as “articles of aluminum, of steel or of copper, nor to derivative aluminum or steel articles provided for in headings 9903.82.02 and 9903.82.04–9903.82.26”.

Set that enumeration beside the one in note 16(c), which names “headings 9903.82.02, 9903.82.04–9903.82.17 and 9903.82.20–9903.82.26”. Both name 9903.82.02 and then open the range at 9903.82.04. The pattern is the same in the two notes, which is what makes it a drafting convention rather than a typographical accident: 9903.82.03 sits outside each enumeration by design. The consequence for an antenna line is clean. An antenna below the weight test reports under 9903.82.03, which is outside the 9903.05.90 carve-out range, so the 10 per cent under 9903.05.44 attaches. An antenna at or above the test reports under 9903.82.09, which is inside the carve-out range, so the 10 per cent falls away and the 25 per cent attaches instead. The omission of 9903.82.03 from the carve-out range is explicit on the face of both notes; your broker applies it on the entry line.

The 15 per cent test, quoted in full

Here is the operative passage from U.S. note 16(c) to subchapter III of chapter 99, HTSUS Revision 20 (2026), with the heading enumeration intact, because the enumeration is doing work:

“Headings 9903.82.02–9903.82.26 apply to the full customs value of articles classifiable in the provisions of the HTSUS enumerated in the following lists. For articles classified in the listed provisions that are not in chapters 72, 73, 74 or 76 of the HTSUS, headings 9903.82.02, 9903.82.04–9903.82.17 and 9903.82.20–9903.82.26 only apply where the weight of the applicable metal is at least 15 percent of the weight of the imported article. The applicable metal is identified in the title of each of the lists below. If an article is classified in a provision that is present on multiple lists, use the aggregate weight of the listed metals.”

Three readings follow from the words as written. First, the base of the duty is the full customs value, stated in the opening sentence, and it is stated once for the whole run of headings. Second, the 15 per cent condition is attached to a named list of headings, not to all of them — 9903.82.03 is outside it, which is consistent with 9903.82.03 being the heading that reports the sub-threshold case, and 9903.82.18 and 9903.82.19 are outside it too. Third, the condition applies only to listed articles falling outside chapters 72, 73, 74 and 76. An antenna in 8517.71.00 is in chapter 85, so the weight test governs it.

Which metal counts

The note says the applicable metal is identified in the title of each list, and that where an article is classified in a provision present on more than one list you use the aggregate weight of the listed metals. That cuts in the importer’s favour here, and it is worth checking rather than assuming. Across all eleven subdivisions of note 16(c) in Revision 20 (2026), 8517.71.00 appears exactly once — in subdivision (vi), Derivative aluminum articles. Only the aluminium mass therefore enters the numerator for an antenna, because 8517.71.00 sits on the aluminium list at (c)(vi) alone.

CBP’s own guidance illustrates the contrast with a different code. Because 8302.10.60 is identified in both the derivative aluminium paragraph and the derivative steel paragraph — and we confirmed it on both, at (c)(vi) and at (c)(vii) — the aggregate weight of aluminium and steel goes into that article’s calculation. An antenna is the simpler case: one list, one metal, one number.

What counts as “the imported article”

The denominator is the article as presented for classification. For an antenna that normally means the radiating element, the ground plane, the housing and radome, the integral connector and any permanently attached pigtail — everything classified together as one antenna. A coaxial cable shipped loose in the same carton is its own article, with its own classification and its own 15 per cent test.

That matters commercially, because several of the other things in a portal carton sit on the very same list. All of these provisions appear in note 16(c)(vi):

Provision on the (c)(vi) listPortal item that commonly ships under it
8517.71.00Antennas and aerial reflectors; parts for them
8302.10.30, 8302.10.60, 8302.20.00, 8302.30, 8302.41, 8302.42.30, 8302.49.60, 8302.50.00, 8302.60 — note that the mountings entries are listed at statistical-suffix level, so check the suffix against the scheduleBase-metal mountings, fittings and brackets
8544.19.00, 8544.42.90, 8544.49.20, 8544.49.90, 8544.60.20, 8544.60.60Insulated conductors and cable, with or without fitted connectors
8536.90.8585Other apparatus for switching or making connections
8538.10.00Boards, panels and consoles for the goods of 8537, not equipped
8504.31.20, 8504.31.40, 8504.31.60, 8504.33.00, 8504.90.41Transformers and parts of transformers

The right-hand column maps each provision to the portal item that commonly ships under it; the governing classification is always the article as presented. The useful point is that a portal shipment can carry several independent 15 per cent tests, and a broker needs a weight fraction for every line that lands on a list.

Worked both ways on one antenna

Take a circularly polarised panel antenna of the kind that goes on a dock-door frame. Stated assumptions, all of which a buyer should replace with their own:

Step 1 — the threshold in grams

0.15 × 2,800 g = 420 g. That is the whole test. Aluminium mass of 420 g or more and the article is at or above 15 per cent; 419 g and it is below.

Step 2 — Case A, aluminium 392 g

392 g ÷ 2,800 g = 0.1400 = 14.00 per cent, which is 28 g below the threshold.

Step 3 — Case B, aluminium 448 g

448 g ÷ 2,800 g = 0.1600 = 16.00 per cent, which is 28 g above the threshold.

LineCase A — 392 g Al (14.00%)Case B — 448 g Al (16.00%)
Chapter 85 classification8517.71.008517.71.00
Column 1 GeneralFree — $0Free — $0
Section 232 heading9903.82.03 — No change9903.82.09 — +25%
Section 232 duty$0$2,250
Section 301 heading9903.05.44 — 10%9903.05.90 — carved out
Section 301 duty$900$0
Total additional duty$900$2,250
Per antenna, 12 units$75.00$187.50

Step 4 — read the gap as a step, not a slope

$2,250 − $900 = $1,350 on a $9,000 line, which is 15.0 per cent of the line, or $112.50 per antenna. The whole $1,350 moves on one gram: at 419 g the article is 14.96 per cent and reports under 9903.82.03; at 420 g it is exactly 15.00 per cent, satisfies “at least 15 percent”, and reports under 9903.82.09. So the figure is a step function, and an antenna at 15.5 per cent aluminium pays the same 25 per cent as one at 40 per cent. Budget it as a switch with two positions rather than as a gradient to interpolate.

Step 5 — the denominator moves too

The test is a ratio, so total mass carries as much weight as aluminium mass. For the 448 g of aluminium in Case B to represent less than 15 per cent, the article as presented would have to weigh more than 448 g ÷ 0.15 = 2,986.7 g — roughly 187 g above the 2,800 g we started with. Whether a design change of that size is sensible is an engineering question rather than a customs one, but it is the reason a material declaration states both masses and the method used to obtain them, rather than a percentage somebody remembers.

Where the reader line sits

The same portal’s reader is assessed on its own footing, and the aluminium measure does not reach into it.

RFID readers are routinely classified in 8471.60.90 or 8517.62.00 depending on how they present. CBP ruling N261367 of 24 February 2015 took a stationary automated RFID tag reading system — a functional unit under Section XVI note 4, comprising a reader, a cellular modem and a solar panel — into 8517.62.0050, and stated plainly that “the rate of duty will be Free”. Ruling N261411 of 2 March 2015 and ruling N010869 of 1 June 2007, the latter on an RFID reader from Australia, both took RFID readers into 8471.60.9050. In Revision 20 (2026) both parent subheadings carry a Column 1 General rate of Free and a Column 2 rate of 35 per cent.

We checked all eleven subdivisions of note 16(c) in Revision 20 (2026), not only the aluminium ones. The listed provisions run to articles of aluminium, steel and copper and their derivatives; 8471.60.90 and 8517.62.00 fall outside every one of those lists. A reader line is therefore assessed on its Column 1 rate at any aluminium weight fraction, and because it is outside the derivative headings it is likewise outside the 9903.05.90 carve-out — which, for an Indian-origin reader entered today, leaves the 10 per cent under 9903.05.44 attaching to that line.

On the two measures examined here, the practical shape of a portal quote into the United States is this: the reader line at 10 per cent; the antenna line at either 10 per cent or 25 per cent, decided by a scale reading. A system is best structured so that readers and antennas are priced, invoiced and documented as the distinct articles they are — which is how we build warehouse portal systems and pallet tracking installations for export, with FCC-band 902–928 MHz and ETSI-band 865–868 MHz variants of the same reader configured per order.

How to price a portal system for the US

Five things, in the order they bite.

  1. Split the antenna lines from the reader lines on the commercial invoice, and state the material composition against each. A single blended “RFID portal kit” line asks your broker to make a call about what the imported article is, and the 15 per cent test is then applied to whatever that call produces. Separate lines keep the determination with the person who has the drawings.
  2. Get the aluminium weight fraction of each antenna model in writing before the purchase order. Ask for three numbers rather than one: total mass of the article as presented in grams, aluminium mass in grams, and the method used. A supplier who returns grams has weighed the article.
  3. Where a design sits within a few per cent of the threshold, treat the weight fraction as a datasheet parameter. It is as much a fact about the product as IP rating or gain, it is stable across a production run, and it is the single number that decides a 15-point swing in the landed cost of that line.
  4. Decide deliberately whether a system ships assembled or as separate articles, because classification follows the article as presented and the derivative list is keyed to the provision. An assembled frame with antennas fixed to it and a loose set of antennas are different presentations, and “which provision?” is settled before “which Chapter 99 heading?” can be.
  5. Put the exposure in the quote. A $9,000 antenna line with a $2,250 Chapter 99 charge behind it is an $11,250 line to the buyer. Quoting it up front keeps a won deal won.

For buyers who want the hardware question answered before the customs question, our manufacturer and exporter page sets out how we quote EXW, FOB, CIF and DDP in USD and what documentation travels with each incoterm.

Documenting the weight fraction

The measure is administered on documents. Three of them do the work, and each belongs to the party that can actually weigh the article it describes.

A material declaration, per model

One page per model, carrying: the model number; total mass of the article as presented, in grams; the applicable metal mass, in grams; the fraction to two decimal places; and the method used to obtain it — weighed sub-assemblies, a bill-of-materials roll-up from part drawings, or both reconciled. Where a part is plated, anodised or a composite, say which mass has been counted and why. Date and sign it, and reissue it whenever the design changes. The declaration is issued by whoever builds and weighs that article, which is why it is specified at the purchase order for each article on the shipment rather than assembled at the port.

On our own side of that: we build the readers and the software in-house, and we specify the antenna configuration per order — so for a portal going to a US buyer the three numbers are fixed in the purchase order documentation at the time the configuration is chosen, line by line, rather than reconstructed at entry.

The declaration travels with the entry pack

Keep the declarations with the commercial invoice and packing list so the broker applies the correct Chapter 99 heading first time. Two mechanical details matter here. CBP’s guidance requires that where heading 9903.82.03 is reported, the aggregate weight of the applicable metal in kilograms is reported as a second quantity on the entry summary line — so the sub-threshold claim is a positive, numeric declaration on the face of the entry. And for subject aluminium and aluminium derivative products, CBP continues to require reporting of the countries of smelt and cast, which means that information travels down your own supply chain from the mill and belongs in the entry pack alongside the mass figures.

A binding ruling where a model sits near the line

Where a design lands within a couple of percentage points of 15 per cent, or where the classification of the article itself is genuinely arguable, the route to certainty is a binding ruling request under Part 177 of the Customs Regulations, 19 C.F.R. 177. Every ruling cited in this article was issued under that part, and each is published in full on CBP’s CROSS database at the URL given in the sources below, so you can read the reasoning rather than a summary of it. A ruling converts a judgement call into a document you can hand a buyer. An asset tracking deployment with a hundred portals is worth that letter.

What to re-check before you budget

Everything above was read off HTSUS Revision 20 (2026) and CBP’s own guidance messages on 3 October 2026. Chapter 99 subchapter III is the most frequently amended part of the schedule and these specific provisions have moved more than once, so carry the date as part of the fact and re-read the live note on the day you enter.

One sentence to carry away: on a US-bound portal shipment the antenna line is the line to ask about, the question is a weight fraction in grams, and the answer belongs on a signed sheet of paper at the purchase order.

Frequently asked questions

Do RFID antennas pay US import duty?

At the ordinary tariff level, no. An antenna classified in HTSUS 8517.71.00 carries a Column 1 General rate of Free in Revision 20 (2026), which CBP confirmed in ruling N345860 of 19 February 2025. The exposure comes from Chapter 99, where 8517.71.00 is a listed derivative aluminium provision at note 16(c)(vi), and from any country-specific measure on the entry.

What is the HS code for an RFID antenna in the United States?

8517.71.00, described in the schedule as “Aerials and aerial reflectors of all kinds; parts suitable for use therewith”, with statistical reporting number 8517.71.0000. The Chapter 85 line in HTSUS Revision 20 (2026) shows Column 1 General Free and Column 2 at 35 per cent. Classification always follows the article as presented, so where an assembly is arguable the route to certainty is a binding ruling under 19 C.F.R. 177.

How does the Section 232 derivative aluminium tariff work?

U.S. note 16(c) to subchapter III of chapter 99 lists the provisions treated as aluminium, steel or copper articles and derivatives, and applies the Chapter 99 headings “to the full customs value” of those articles. Where a listed article falls outside chapters 72, 73, 74 and 76, headings 9903.82.02, 9903.82.04–9903.82.17 and 9903.82.20–9903.82.26 apply only where the applicable metal is at least 15 per cent of the weight of the imported article. For an antenna in note 16(c)(vi) made from imported metal, the heading is 9903.82.09, at the subheading duty plus 25 per cent.

What counts as 15 per cent aluminium by weight?

Aluminium mass divided by the total mass of the imported article as presented. For 8517.71.00 only the aluminium mass enters the numerator, because that provision sits on the aluminium list at note 16(c)(vi) alone. On a 2.8 kg antenna the threshold is 0.15 × 2,800 g = 420 g, and the whole duty difference turns on one gram either side of it.

Is the 50 per cent charged on the aluminium content or the whole value?

Two things to separate. Note 16(c) applies these headings to the full customs value rather than to the metal content, so the base is the whole value of the line. And the 50 per cent heading, 9903.82.02, reaches note 16(c)(i) to (c)(v). An antenna sits in (c)(vi), where the residual heading for imported metal is 9903.82.09 at the subheading duty plus 25 per cent.

Does the aluminium tariff apply to RFID readers too?

Readers are typically classified in 8471.60.90 or 8517.62.00 — see CBP rulings N261367 of 24 February 2015, N261411 of 2 March 2015 and N010869 of 1 June 2007 — and both subheadings fall outside all eleven subdivisions of the note 16(c) lists in HTSUS Revision 20 (2026). Both carry a Column 1 General rate of Free and a Column 2 rate of 35 per cent on their Chapter 84 and Chapter 85 lines. The reader line is assessed on its own footing, independently of the antenna line.

How do I prove the aluminium weight fraction of an antenna to customs?

With a dated, signed material declaration per model giving total mass in grams, aluminium mass in grams, the resulting fraction and the method used, kept with the commercial invoice and packing list. Where heading 9903.82.03 is reported, CBP requires the aggregate weight of the applicable metal in kilograms as a second quantity on the entry summary line, and the countries of smelt and cast continue to be reportable for subject aluminium and aluminium derivative products.

Sources

Related Identium Pages

Pricing a US-bound portal and want the hardware side settled first? Our RFID manufacturer and exporter page covers OEM and ODM builds, USD quotes on EXW, FOB, CIF and DDP terms, and the documentation that travels with each. For the application itself, see RFID Warehouse Management for dock-door and inventory deployments, and RFID Pallet Tracking where the read happens at the pallet rather than the item. We build the readers and the software in-house and specify the antenna configuration per order, so the three numbers a US entry needs — total mass, applicable metal mass, and the method used — are settled line by line at the purchase order rather than reconstructed at the port.

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