Jay Allan
Licensed Customs Broker
Consolidated Metco, Inc.
5701 SE Columbia Way
Vancouver, WA 98661

RE: The tariff classification a rotor assembly from China.

Dear Mr. Allan,

In your letter dated August 8, 2018, you requested a tariff classification ruling. Descriptive literature and pictures were submitted with your request.

The item under consideration is Rotor Assembly (Part Number 29919998), used in Class 8 heavy duty trucks. The rotor assembly is composed of a disc brake rotor and an anti-lock braking system (ABS) ring, press fit into the inner space of the rotor. The brake rotor is an iron ductile inner mounting ring with an over-molded grey iron brake rotor and with a machined finished surface where the brake pads make contact. The ABS ring is made of steel.

You suggested classification of the rotor assembly in subheading 8708.30.5090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other parts of brakes. General Note 3. (h) (vi) to the HTSUS states “ ... a reference to ‘headings’ encompasses subheadings indented thereunder.” Subheading 8708.30.5030 provides specifically for brake rotors. The ABS ring does not in any way change the rotor’s function or its identity as a rotor.

You also suggested 8543.90.8885, HTSUS, as an alternative classification.  Heading 8543 requires that the machines and apparatus classified in this heading are electrical, having an individual function, and are not specified elsewhere.  As the mechanical brake rotor is more suitably classified in heading 8708, and Section XVI Note 1(l) excludes articles of Section XVII, classifying the rotors in heading 8543 is not appropriate.

The applicable subheading for the Rotor Assembly (Part Number 29919998), will be 8708.30.5030, HTSUS, which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Brakes and servo-brakes; parts thereof: For other vehicles: Brake rotors (discs).” The general rate of duty will be 2.5%, 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, please contact National Import Specialist Liana Alvarez at


Steven A. Mack
National Commodity Specialist Division