CLA-2-73:OT:RR:NC:N1:164
Kevin Vissotski
Associated Spring
16811 Yellowstone Drive
Northville, MI 48168
RE: The tariff classification of engine valve springs from Mexico
Dear Mr. Vissotski:
In your letter dated May 6, 2025, you requested a tariff classification ruling on engine valve springs from
Mexico. Technical information was submitted with your request.
The items under consideration are described as engine valve springs specifically designed for use in internal
automotive combustion engines. During engine operation, the engine valve springs function to keep the
engine’s valves closed when they are not opened by the camshaft. You assert that this function is integral to
maintain proper valve timing and combustion efficiency. In addition, the subject valve springs and raw
materials are highly engineered, tested, and certified to operate under extreme conditions such as heat,
pressure, and high-speed cyclic loading. You state that the material undergoes specialized manufacturing
processes such as shot peening and surface nitriding to ensure durability and reliability. As you subsequently
clarified, the subject valve springs are helically coiled alloy steel wire such as chrome silicon valve quality,
chrome silicon vanadium valve quality, and chrome silicon vanadium nickel valve quality. Depending on the
application, the wire diameter ranges from approximately 1 to 3 millimeters (mm).
In your letter, you suggest classification of the engine valve springs in subheading 8409.91.99, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for “Parts suitable for use solely or principally
with the engines of heading 8407 or 8408: Other: Suitable for use solely or principally with spark-ignition
internal combustion piston engines (including rotary engines): Other: Other:” We disagree.
Classification of merchandise under the HTSUS, is in accordance with the General Rules of Interpretation
(GRIs), taken in order. GRI 1 provides that classification shall be determined according to the terms of the
headings and any relative section or chapter notes. Note 1(g) to Section XVI excludes “Parts of general use,”
as defined in Note 2(b) to Section XV. This definition includes articles such as springs and leaves for springs,
of base metal.
Furthermore, Additional U.S. Rule of Interpretation 1(c) states that, in the absence of special language or
context which otherwise requires, “a provision for parts of an article covers products solely or principally
used as part of such articles but a provision for ‘parts’ or ‘parts and accessories’ shall not prevail over a
specific provision for such part or accessory.” Accordingly, since heading 7320 is an eo nomine provision for
springs, it will take precedence over heading 8409, which is a provision for parts.
The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official
interpretation of the HTSUS. While not legally binding nor dispositive, the ENs provide a commentary on the
scope of each heading of the HTSUS and are generally indicative of the proper interpretation of these
headings. See T.D. 89-80, 54 Fed. Reg. 35127 (August 23, 1989).
The ENs to heading 7320 reaffirm Note 2(b) to Section XV by stating “The heading covers iron or steel
springs of all types, irrespective of their use, other than clock or watch springs of heading 91.14. Springs are
made from sheet metal, wire or rod of an elastic quality, in such a way that they have the property of
returning to their original form even after considerable displacement.” Noting this, heading 7320, HTSUS,
provides for all iron or steel springs, even those which are specifically designed or intended for use in internal
automotive combustion engines.
The applicable subheading for the engine valve springs will be 7320.20.5020, HTSUS, which provides for
“Springs and leaves for springs, of iron or steel: Helical springs: Other: Helical springs, of wire having a
cross-sectional dimension of less than 5.1 mm: Other.” The general rate of duty will be 3.9 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 7320.20.5020,
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 7320.20.5020.
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 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 7320.20.5020, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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
(C.F.R.), 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 C.F.R. 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 Paul Taylor at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division