CLA-2-87:OT:RR:NC:N2 206
Hyunwook Choi
Daehan Solution Co., Ltd.
30, Namdong-daero 369 beon-gil, Namdong-gu,
Incheon 21629
South Korea
RE: The tariff classification of sound damping material for passenger vehicles from South Korea
Dear Mr. Choi:
In your letter dated April 13, 2025, you requested a tariff classification ruling.
The merchandise under consideration is referred to as Heel_Kick Pad LH_01, Part number
WA56CA13003A, which is a sound damping material cut into a predetermined shape to fit under the floor
covering of a passenger vehicle. The item is composed of 40% polyester staple fiber (low melting fiber), 40%
polyester staple fiber (regular fiber), and 20% polyester regenerated staple fiber (recycled fiber) with
dimensions of 37.4 inches (L) x 4.92 inches (W) x 0.59 inches (D). This item is a component that attaches to
a specific mounting point under the floor covering (carpet assembly) which sits on top of the floor pan of a
vehicle. The sound damping material is attached to the underside of the floor covering to reduce the road
noise.
The applicable subheading for the Heel_Kick Pad LH_01, Part number WA56CA13003A, will be
8708.29.5160, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and
accessories of the motor vehicles of heading 8701 to 8705: Other parts and accessories of bodies (including
cabs): Other: Other: Other.” The rate of duty will be 2.5 percent ad valorem.
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. At the time of entry, you must
report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to
subheading 8708.29.5160, 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