CLA-2-94:OT:RR:NC:N5:433
Kyung-Jin Moon
Jinsol Customs Consulting & Logistic Service
129, Gaetbeol-ro, Yeonsu-gu,
Incheon 21999
South Korea
RE: The tariff classification of an automobile seat component from South Korea.
Dear Kyung-Jin Moon:
In your letter dated July 6, 2025, on behalf of SEOYON E-HWA, you requested a tariff classification ruling.
In lieu of samples, technical and illustrative literature, a product description, and manufacturing processes
were provided.
Item 84660-P6A00NNB, the “Seat Armrest Assembly,” is a composite seat component constructed of
aluminum metal, polyurethane foam, and pre-cut synthetic leather with stitched seams that will be installed
adjacent to the driver and front passenger automobile seat of motor vehicles according to Original Equipment
Manufacturer (OEM) specifications. Documentation provided states, “[I]t is designed as a component of the
automotive seat, allowing occupants to rest their arms comfortably while driving or at rest.” Dependent on
OEM specification, certain seat armrest assemblies will incorporate hinges or mounting brackets.
Consideration was given to classifying the armrest assembly in subheading 8708.29, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for parts and accessories of motor vehicle bodies, as
you suggested. We disagree.
Although the armrest assembly is not directly affixed to the vehicle seats, it serves as a component of the
seats by providing comfort to the driver and passenger, allowing them to rest their arms while sitting. In
Mitsubishi Electronics America v. United States, 19 CIT 378, 383 n.3 (1995) the court stated, “…a subpart of
a particular part of an article is more specifically provided for as a part of a part than a part of the whole”. As
a result, it is the opinion of this office that the armrest assembly is more specifically provided for as a part of
seats than a part of vehicle bodies. Therefore, classification of the armrest assembly in subheading 8708.29,
HTSUS, is precluded.
The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitutes the
official interpretation of the Harmonized System at the international level.
The ENs to Chapter 94 of the Harmonized Tariff Schedule (HTS), for “Parts,” provides: “This Chapter only
covers parts, whether or not in the rough, of goods of heading 9401 to 9403 and 9405, when identifiable by
their shape or other specific features as parts designed solely or principally for an article of those headings.
They are classified in this Chapter when not more specifically covered elsewhere.”
Further, Chapter 94, Legal Note 2 provides: “The articles (other than parts) referred to in headings 9401 to
9403 are to be classified in those headings only if they are designed for placing on the floor or ground.” The
restriction on “furniture” being floor or ground standing does not apply to (parts) of furniture.
The seat armrest assembly metal components are fabricated to shape and the polyurethane foam and the
synthetic leather components are cut to shape. Prior to fabrication and assembly, the unassembled
components are designed specifically for automobile seats of heading 9401 HTS and are not more
specifically provided for elsewhere. In view of these facts, the seat armrest assembly is a dedicated article
identifiable by a specific shape or specific feature as being designed solely or principally for automobile seats
in-so-much as they are integral, constituent or component parts.
The applicable subheading for the subject merchandise will be 9401.99.1085 HTSUS, which provides for
“Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Parts:
Other: Of seats of a kind used for motor vehicles: Other.” The general rate of duty will be free.
Trade Remedy:
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 9401.99.1085, 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 Dharmendra Lilia at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division