CLA-2-84:OT:RR:NC:N1:103
Estela Clemenz Clark
Senior Operations LLC
300 E Devon Ave.
Bartlett, IL 60103
RE: The tariff classification of machined castings from India
Dear Ms. Clemenz Clark:
In your letter dated June 4, 2025, you requested a tariff classification ruling.
The merchandise under consideration is referred to as an inlet port, part number 5805-038-305, and an outlet
port, part number 5805-038-504, for an exhaust gas recirculation (EGR) system cooler, a device designed to
cool exhaust gases before they enter the intake manifold of a diesel engine. The EGR cooler is configured as
a shell and tube heat exchanger, where exhaust gases flow through the tube side of the unit and coolant flows
around the tubes in the shell side.
The inlet port and outlet port are described as finished stainless-steel castings that have been machined to
their final tolerances. The inlet port serves as the point where coolant enters the EGR cooler while the outlet
port functions as the point where coolant exits the assembly. Post-importation, both castings are welded to
the housing of the EGR cooler.
The applicable subheading for the inlet port, part number 5805-038-305, and the outlet port, part number
5805-038-504, will be 8419.90.3000, Harmonized Tariff Schedule of the United States (HTSUS), which
provides for “Machinery, plant or laboratory equipment, whether or not electrically heated (excluding
furnaces, ovens and other equipment of heading 8514), for the treatment of materials by a process involving a
change of temperature such as heating, cooking, roasting, distilling, rectifying, sterilizing, pasteurizing,
steaming, drying, evaporating, vaporizing, condensing or cooling, other than machinery or plant of a kind
used for domestic purposes; instantaneous or storage water heaters, nonelectric; parts thereof: Parts: Of heat
exchange units.” The general rate of duty will be free.
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. 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
8419.90.3000, 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 Paul Huang at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division