CLA-2-87:OT:RR:NC:N2:206
Aida Aguilar
Barajas Customs Brokerage Co.
302 Quivira Drive
Laredo, TX 78046
RE: The tariff classification of automotive heat deflectors from Mexico
Dear Mr. Aguilar:
In your letter dated April 10, 2025, you requested a tariff classification ruling, on behalf of your client
Carcoustics Industrial de Mexico S. de RL.
The article under consideration is an Automotive Heat Deflector (Part Number 5B51A31), which is used in
light trucks. The heat deflector is made of aluminum coils that undergo cutting, forming, and perforating. It is
shaped in a specific configuration that allows it to be fitted on the external part of the chassis. The function of
the heat deflector is to dissipate heat from the engine.
The applicable subheading for the Automotive Heat Deflector (Part Number 5B51A31) will be
8708.99.8180, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and
accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other:
Other: Other: Other.” The general rate of duty will be 2.5 percent ad valorem.
Products of Mexico as provided by heading 9903.01.01 in Section XXII, Chapter 99, Subchapter III, U.S.
Note 2(a), HTSUS, other than products classifiable under headings 9903.01.02, 9903.01.03, 9903.01.04, and
9903.01.05, HTSUS, will be subject to an additional 25 percent ad valorem rate of duty. At the time of entry,
you must report the applicable Chapter 99 heading, i.e. 9903.01.01, in addition to subheading 8708.99.8180,
HTSUS, listed above. Articles that are entered free of duty under the terms of general note 11 to the HTSUS
(U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set forth in subchapter XXIII of
Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be subject to the additional ad valorem
duties provided for in heading 9903.01.01. If your product is entered duty free as originating under the
USMCA, you must report heading 9903.01.04, HTSUS, in addition to subheading 8708.99.8180, HTSUS.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. ?Products from all other
countries will be subject to an additional 10 percent ad valorem rate of duty. Your product falls within an
excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e.9903.01.27, in addition to subheading 8708.99.8180, HTSUS, listed above.
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/.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
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 Liana Alvarez at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division