Messrs. Christopher M. Kane and Daniel J. Gluck
Simon Gluck & Kane LLP
250 West 34th Street - Suite 4615
One Penn Plaza
New York, NY 10119

RE: The tariff classification of Winch Cargo Securing Devices from China

Dear Messrs. Kane and Gluck:

In your letter dated January 28, 2015, on behalf of your client, Kinedyne Corporation, you requested a tariff classification ruling.

The winch (model number 1020) is constructed from medium carbon steel plate with precision cast steel pawls and gears. The winch consists of a round gear drum with teeth. The teeth are uniform but are asymmetrical with each tooth having a moderate slope on one edge and a steeper slope on the other edge. When the teeth are moving in a forward direction, the steel pawl allows the depression between the teeth to click easily as it passes the tip of each tooth. When the teeth move in the opposite direction, the pawl catches the sloped edge of the first tooth it encounters, thereby locking it against the tooth, preventing any movement and securing the winch strap and chain anchor in place over the cargo load. The winch is used on a flatbed truck for safe securing of cargo. The winch is manufactured to accommodate webbing straps up to four inches in width and may be used with webbing straps, cable or a combination of the two. The winch consists of a hand-operated horizontal ratchet drum around which webbing and/or cable is wound.

The four inch wide winch strap with integrated chain anchor (part number 422740) is a composite good. The woven winch strap is made from high tenacity polyester fibers using a double plain weaving method and is treated with a urethane resin for strength and durability. The chain anchor is permanently attached to the strap and consists of eleven quarter inch welded closed links with a heavy forged steel hook permanently attached to the eleventh closed link.

You have requested a tariff classification ruling under the following three scenarios: A) the winch (model number 1020) imported together with the strap and chain anchor (part number 422740), B) the winch imported without the strap and chain anchor and C) the strap and chain anchor imported separately.

Samples provided to this office of the steel winch and the strap and chain anchor will be returned as requested.

Under scenarios A and B, the applicable subheading for the steel winch (model number 1020) imported together with the strap and chain anchor (part number 422740), and the winch imported separately will be 8425.39.0100, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Pulley tackle and hoists other than skip hoists, winches and capstans; jacks. Winches; capstans: Other”. The rate of duty will be free.

Under scenario C, the applicable subheading for the winch strap and chain anchor (part number 422740), if imported separately, will be 6307.90.9889, HTSUS, which provides for “Other made up articles, including dress patterns: Other: Other: Other: Other: Other.” The duty rate will be 7 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

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 Patricia O’Donnell at [email protected].


Gwenn Klein Kirschner
National Commodity Specialist Division