CLA-2-84:OT:RR:NC:N1:104
Kenny Franco
KSF Property Management, Inc
90 Chestnut Meadow Dr.
Conroe, TX 77384
RE: The tariff classification of equine exercise machines from China
Dear Mr. Franco:
In your letter dated July 11, 2025, you requested a tariff classification ruling.
The products in question are three models of the Reeds Horse Exercise machine, model numbers RDTM07,
RDTM12, and RDTM30. The machines resemble large human treadmill exercisers. These machines are
comprised of a steel “W” (wide flange) beam main frame which supports steel rollers that turn a rubber
treadmill track, and sides and handrails of galvanized steel plating and pipe. The rollers are driven by an
electric motor coupled to a gearbox driven by a variable frequency drive (VFD), permitting a range of speeds
from 0-18 mph. The machines also include a hydraulic pump/motor connected to two hydraulic pistons that
raise one end of the machine for inclined exercising. Steel entrance and exit ramps for the machines are
included in the importation. Finally, the machines include a control box that contains the VFD, start/stop
pushbuttons, LCD speed display, and speed and incline selector knobs. The machines weigh approximately
3,600 lbs. and measure 67" (W) x 161" (L) x 85" (H).
In operation, a horse handler loads the horse onto the machine’s rubber track, then secures the horse through
the bridle to the machine’s rails. The operator can adjust the speed and incline of the machine to vary the
animal’s exercise experience including flat running, uphill walking, speed walking, etc.
The applicable subheading for the Reeds Horse Exercise machines will be 8479.89.9599, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for “Machines and mechanical appliances having
individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and
mechanical appliances: Other: Other: Other.” The general rate of duty will be 2.5 percent ad valorem.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 8479.89.9599, 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. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e., 9901.01.25, in addition to subheading
8479.89.9599, HTSUS, listed above.
Products of China classified under subheading 8479.89.9599, HTSUS, unless specifically excluded, are
subject to the additional 25 percent ad valorem rate of duty. At the time of importation, you must report the
Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8479.89.9599, 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 Arthur Purcell at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division