CLA-2-84:OT:RR:NC:N1:103

Santos Sanjuan
The 346 Company, LLC
5900 Balcones Dr., Ste. 12781 Austin, TX 78731

RE: The tariff classification of dozer blades from China

Dear Mr. Sanjuan:

In your letter dated May 20, 2023, you requested a tariff classification ruling.

The items under consideration are referred to as steel dozer blades that are mounted along the bottom edge of a moldboard, which is designed for various models of Komatsu dozers.  Once installed, the blades form a cutting edge along the moldboard.  Part number 12Y-72-11210, identified as the End Bit, measures 20mm by 203mm by 378mm and weighs 11.5 kgs.  Part number 12Y-72-11220, identified as the Center, measures 20mm by 203mm by 762mm and weighs 22 kgs.  Part number 12Y-72-11230 measures 20mm by 203mm by 914.4mm and weighs 26.5 kgs.  Each blade is imported with the required number of plow bolts and nuts to mount the blades. 

The applicable subheading for the dozer blades, part numbers 12Y-72-11210, 12Y-72-11220, and 12Y-72-11230, will be 8431.49.9095, Harmonized Tariff Schedule of the United States (“HTSUS”), which provides for “Parts suitable for use solely or principally with the machinery of headings 8425 to 8430: Of machinery of heading 8426, 8429 or 8430: Other: Other: Other: Other: Other: Other: Other.”  The rate of duty will be free.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8431.49.9095, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty.  At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01, in addition to subheading 8431.49.9095, HTSUS, listed above.

The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading.  For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.

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 at https://hts.usitc.gov/current

This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Paul Huang at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division