CLA-2-87:OT:RR:NC:N2:206
Changgyu Kim
SEIN Customs & Auditing Corp
138, Seoun-ro, Seocho-gu,
Seoul 06619
South Korea
RE: The tariff classification of a strut mount from South Korea
Dear Mr. Kim:
In your letter dated May 31, 2025, you requested a tariff classification ruling.
The article under consideration is described as a Strut Mount, part number SZ437-B72-01, which is used in a
KIA EV9 model. It consists of a plastic bearing, an aluminum alloy bracket and upper lid, a carbon steel
inner plate, a rubber dampener, a plastic outer pipe, and a steel serration bolt. It measures 167.6 mm x 53.7
mm. The strut mount serves to secure the suspension to the chassis and absorbs shocks and vibrations
transmitted from the road surface, thereby improving ride comfort. It is mounted at the uppermost part of a
vehicle's rear suspension strut assembly and connects the entire strut assembly to the chassis.
You suggested classification of the strut mount in subheading 8708.99.8180, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for motor vehicle parts, not specified otherwise. We disagree.
Although you state that the strut mount is an integral component of the suspension system, you assert that it
cannot be regarded as a specific and principal component, such as ‘Suspension systems’ or ‘Shock
absorbers’, as stipulated in 8708.80, HTSUS. However, the subheading not only provides for suspension
systems and shock absorbers, but also for parts. As a result, subheading 8708.99 will not apply to the strut
mount at issue.
The applicable subheading for the Strut Mount, part number SZ437-B72-01 will be 8708.80.6590, HTSUS,
which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Suspension
systems and parts thereof (including shock absorbers): Parts: Other: Other: 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
8708.80.6590, 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 8708.80.6590, 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 Liana Alvarez at [email protected].
Sincerely,
James Forkan
Acting Director
National Commodity Specialist Division