CLA-2-84:OT:RR:NC:N1:102

Minji Kim
Hyundai Transys Georgia Powertrain, Inc.
6801 Kia Parkway
West Point, GA 31833

RE: The tariff classification of a valve body assembly and a valve body frame from Mexico

Dear Ms. Kim:

In your letter dated April 29, 2025, you requested a tariff classification ruling on two items.

The first item at issue is referred to as a valve body assembly, part number SS46210-4G800M2. The assembly is a valve comprised of layered aluminum alloy housings that feature precisely machined passages and components, such as various spool valves, check valves, pistons, springs and two separator plates. The solenoids that are intended to be incorporated with their respective valves are imported separately. The valve body assembly is used within the transmission system of a motor vehicle.

Subheading Note 3 to Chapter 84 states for the purposes of subheading 8481.20, the expression “valves for oleohydraulic or pneumatic transmissions” means valves which are used specifically in the transmission of “fluid power” in a hydraulic or pneumatic system, where the energy source is supplied in the form of pressurized fluids (liquid or gas). These valves may be of any type. Subheading 8481.20 takes precedence over all other subheadings of heading 8481.

Accordingly, the applicable subheading for the valve body assembly will be 8481.20.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Valves for oleohydraulic or pneumatic transmissions: Hydraulic valves: Other. The general rate of duty is 2 percent ad valorem.

The second item is referred to as a valve body frame, identified by part numbers INR: 46213-T87810L, MDL: 46214-T87810L and OTR: 46215-T87810L. The valve body is an aluminum alloy housing that features precisely machined passages and inserts specifically designed to incorporate separately imported springs, pistons and valves. The valves control the flow and direction of hydraulic fluid within a transmission system of a motor vehicle. The applicable subheading for the valve body frame will be 8481.90.9020, HTSUS, which provides for Taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Parts: Other: Of valves of subheading 8481.20: Valve bodies. The general rate of duty will be Free.

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 8481.20.0050 or 8481.90.9020, 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 8481.20.0050 or 8481.90.9020, HTSUS, listed.

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. At this time products from all countries will be subject to an additional 10 percent ad valorem rate of duty. Your products fall 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 8481.20.0050 or 8481.90.9020, 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 Sandra Martinez at [email protected].
Sincerely,

(for)
Steven A. Mack
Director
National Commodity Specialist Division