CLA-2-40:OT:RR:NC:N5:137
Hae Jun Kwon
Hyundai Motor Company
231, Yangjae-dong, Seocho-gu
SEOUL 06797
Korea, South
RE: The tariff classification of EPDM rubber automotive door glass runs from South Korea
Dear Mr. Kwon:
In your letter dated May 21, 2025, you requested a tariff classification ruling.
Part Number 82501-AR000, MLDG & RUN ASSY-FR DR FRM, LH and Part Number 82502-AR000,
MLDG & RUN ASSY-FR DR FRM, RH, are automotive door glass runs composed of compact ethylene
propylene diene monomer (EPDM) rubber coextruded with a steel insert. The products are shaped to fit the
side door glass frame of the automobile that comes in contact with the glass window. The glass runs serve as
a guide when the window goes up and down. They maintain air and water tightness between the glass and
frame while also absorbing external noise and door glass vibrations while driving or when the door is closed.
Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is in
accordance with the General Rules of Interpretation (GRIs). GRI 3(b) provides that mixtures, composite
goods consisting of different materials or made up of different components, and goods put up in sets for retail
sale shall be classified as if they consisted of the material or component which gives them their essential
character, which may be determined by the nature of the material or component, its bulk, quantity, weight or
value, or by the role of a constituent material in relation to the use of the article. We find that the automotive
door glass runs are composite goods. The door runs form a seal between the door frame and the glass to
prevent leakage as well as absorb external noise and door glass vibrations. It is the EPDM rubber component
that facilitates these actions; therefore, the essential character of these door glass runs is imparted by the
EPDM rubber component.
The applicable subheading for the EPDM rubber automotive door glass runs will be 4016.93.1050,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of vulcanized
rubber other than hard rubber: other: gaskets, washers and other seals: of a kind used in the automotive goods
of chapter 87: other. The general 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. At this time products from all countries,
including South Korea, 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 4016.93.1050, 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
(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 Christina Allen at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division