CLA-2-84:OT:RR:NC:N1:102
Thomas Goatley
Kelford Cams
15 Kennaway Road
Christchurch, Woolston 8023
New Zealand
RE: The tariff classification of camshafts from New Zealand
Dear Mr. Goatley:
In your letter dated May 28, 2025, you requested a tariff classification ruling.
The products in question are referred to as camshaft sets, stock keeping unit numbers 256-A, 264-A, 258-A,
273-A and 179-A. The sets consist of two shafts with lobes that rotate to convert rotational motion into linear
motion for the purpose of opening and closing engine valves. One shaft is designed to operate with the intake
valves and the other operates with the exhaust valves. The steel shafts, which rotate in synchrony with the
crankshaft, are used in spark-ignition internal combustion engines of high-performance motorsport
applications, e.g. passenger vehicles, trucks and sports utility vehicles.
In your letter, you suggest the camshaft sets are classified within subheading 8409.91.50, 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: Other: Other. We disagree.
The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official
interpretation of the Harmonized System at the international level. 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. In this instance, the ENs to heading 8409 state, “Subject to the
general provisions regarding the classification of parts, this heading covers parts of internal combustion
piston engines of heading 8407 or 8408 (e.g., pistons, cylinders and cylinder blocks; cylinder heads; cylinder
liners; inlet or exhaust valves; inlet or exhaust manifolds; piston rings; connecting rods; carburetors; fuel
nozzles).” However, the heading excludes engine camshafts of heading 8483.
Furthermore, Additional U.S. Rule of Interpretation 1(c) explains that a provision for parts of an article
covers products solely or principally used as a 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. As such, the camshafts are
classified within heading 8483, HTSUS, which specifically provides for transmission shafts, including
camshafts and crankshafts.
With respect to whether the camshaft sets are classified as a set for classification purposes. Explanatory Note
(X) to General Rule of Interpretation 3(b) states that the term “goods put up in sets for retail sale” means
goods that: (a) consist of at least two different articles which are, prima facie, classifiable in different
headings; (b) consist of articles put up together to meet a particular need or carry out a specific activity; and
(c) are put up in a manner suitable for sale directly to users without repacking.
In this instance, the camshaft sets are not classified as a set, as the set does not consist of at least two different
articles that are classified in different headings. Each camshaft is classified within heading 8483, HTSUS.
Accordingly, the applicable subheading for the individual camshafts will be 8483.10.1030, HTSUS, which
provides for Transmission shafts (including camshafts and crankshafts) and cranks; bearing housings, housed
bearings and plain shaft bearings; gears and gearing; ball or roller screws; gear boxes and other speed
changers, including torque converters; flywheels and pulleys, including pulley blocks; clutches and shaft
couplings (including universal joints); parts thereof: Transmission shafts (including camshafts and
crankshafts) and cranks: Camshafts and crankshafts: Designed for use solely or principally with
spark-ignition internal combustion piston engines or rotary engines: For vehicles of chapter 87: Other. The
general rate of duty will be 2.5 percent ad valorem.
Effective May 3, 2025, Presidential proclamation 10908 imposed additional tariffs on certain automobile
parts. Additional duties on automobile parts of 25 percent are reflected in Chapter 99, heading 9903.94.05, as
provided in subdivision (g) of U.S. note 33 to this subchapter. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e., 9903.94.05, in addition to subheading
8483.10.1030, HTSUS, listed above.
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., 9903.01.33, in addition to subheading 8483.10.1030, 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 Sandra Martinez at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division