CLA-2-84:OT:RR:NC:N:1:118
9903.88.03; 9903.88.15
Robert Grasing
Sandler, Travis & Rosenberg P.A.
24 Smith St., Building 2, Suite 102
Pawling, NY 12564
RE: The tariff classification of parts of a lawn mower and subassemblies for a lawn mower from China
Dear Mr. Grasing:
In your letter dated July 11, 2025, you requested a tariff classification ruling on behalf of your client, MTD
Consumer Group Inc., DBA MTD Products Inc. The products under consideration are various parts and
subassemblies used to manufacture an electrically powered walk behind lawn mower. You have stated that
they will be imported separately in bulk. After importation, the parts and subassemblies will be placed in
inventory where they will be pulled as needed to assemble a finished lawn mower.
The products that are the subject of this ruling request consist of the following:
Deck Subassembly: This subassembly will consist of the deck, which is the outer housing/cover for the
mower, a plastic clip, which is the main mounting hub, the front and rear axle, rear door, handle mounting
brackets, height adjustment mechanism, and trail shield. For self-propelled walk behind mowers, the deck
subassembly will also include the transmission, which is essentially a drive system that will be powered by
the motor to power the wheels and propel the mower forward. The deck subassembly will be imported in two
configurations. In one configuration it will be imported without the powerhead, while in the second scenario
it will be imported already assembled with the powerhead (i.e. the electric motor).
Handle Set: This is a subassembly consisting of a combination of structural and electrical components. The
structural components will consist of the following steel/plastic components:
Handle Tubes (made from 100% steel)
Handle Panel / Switch Box Housing (plastic)
Blade Control Housing – (steel or plastic)
Drive Control Housing – (steel or plastic)
Key – (plastic or plastic with magnet)
Handle folding hardware – (steel and plastic)
Miscellaneous hardware (for example, nuts, bolts, springs, etc.) – (steel).
The electrical components will consist of the following:
Wire harness
Electrical switches
Electrical connectors
Display Panel – (a printed circuit board assembly)
This subassembly will be imported completely assembled and ready for final assembly in the United
States.
Wheels: The majority of the wheels that will be imported are comprised of two pieces: a plastic rim
combined with a plastic/rubber tread. A smaller number of wheels will feature a one-piece construction
consisting of a combined plastic rim and tread. They will be imported in their finished state ready for final
assembly in the United States.
Blades: These are the steel blades for the finished lawn mower. They will be imported in their finished state
ready for final assembly in the United States.
You suggested classifying the deck subassembly, imported already assembled with the powerhead, as a part
of a lawnmower within subheading be 8433.90.1090, Harmonized Tariff Schedule of the United States
(HTSUS). We disagree. Classification under the HTSUS is made in accordance with the General Rules of
Interpretation (GRIs). GRI 1 provides that the classification of goods shall be determined according to the
terms of the headings of the tariff schedule and any relative section or chapter notes. If the goods cannot be
classified solely based on GRI 1, and if the headings and legal notes do not otherwise require, GRIs 2 through
6 may then be applied in order. GRI 2(a) provides, in pertinent part, that any “reference in a heading to an
article shall be taken to include a reference to that article incomplete or unfinished, provided that, as entered,
the incomplete or unfinished article has the essential character of the complete or finished article.”
Merchandise classifiable under heading 8433, HTSUS, includes not only complete, fully assembled lawn
mowers, but also "incomplete" lawn mowers (provided that, as entered, any such “incomplete” machinery
has the essential character of a complete machine). You stated in your submission that when the deck
subassembly is imported already assembled with the powerhead, the only post-importation assembly
operations needed to complete a finished lawn mower are attaching the wheels, blades and handle sets, along
with quality control testing and packaging. It is therefore our opinion that the deck subassembly imported
already assembled with the powerhead, constitutes an “incomplete machine,” and as such, can be classified
as a finished lawn mower.
In accordance with GRI 2(a) the applicable subheading for the deck subassembly imported assembled with
the powerhead, will be 8433.11.0010, HTSUS, which provides for harvesting or threshing machinery,
including straw or fodder balers; grass or hay mowers…, parts thereof: mowers for lawns, parks or sports
grounds: powered, with the cutting device rotating in a horizontal plane: electric mowers, including battery
operated. The general rate of duty will be free.
“Parts” are classified in accordance with Note 2 to Section XVI of the HTSUS, which states that, subject to
certain exclusions found in Note 1 to Section XVI, Note 1 to Chapter 84 and Note 1 to Chapter 85, parts of
machines (not being parts of the articles of heading 8484, 8544, 8545, 8546 or 8547) are to be classified
according to the following rules:
(a) Parts which are goods included in any of the headings of chapters 84 and 85 (other than headings
8409, 8431, 8448, 8466, 8473, 8487, 8503, 8522, 8529, 8538 and 8548) are in all cases to be
classified in their respective headings…
(b) Other parts, if suitable for use solely or principally with a particular kind of machine, or with a
number of machines of the same heading (including a machine of heading 8479 or 8543) are to be
classified with the machines of that kind or in heading 8409, 8431, 8448, 8466, 8473, 8503, 8522,
8529 or 8538 as appropriate. However, parts which are equally suitable for use principally with the
goods of headings 8517 and 8525 to 8528 are to be classified in heading 8517;
(c) All other parts are to be classified in heading 8409, 8431, 8448, 8466, 8473, 8503, 8522, 8529 or
8538 as appropriate or, failing that, in heading 8487 or 8548.
The deck subassembly (imported without the powerhead) and handle set are both subassemblies of an
electrically powered walk behind lawn mower that is classified within Heading 8433, HTSUS. Therefore, in
accordance with Note 2(b) to Section XVI, the applicable subheading for the deck subassembly (imported
without the powerhead) and handle set will be 8433.90.1090, HTSUS, which provides for harvesting or
threshing machinery, including straw or fodder balers; grass or hay mowers; machines for cleaning, sorting or
grading eggs, fruit or other agricultural produce, other than machinery of heading 8437; parts thereof: parts:
of mowers for lawns, parks or sports grounds: other. The general rate of duty will be free.
In accordance with Note 2(b) to Section XVI, the applicable subheading for the wheels will be 8433.90.1010,
HTSUS, which provides for harvesting or threshing machinery, including straw or fodder balers; grass or hay
mowers; machines for cleaning, sorting or grading eggs, fruit or other agricultural produce, other than
machinery of heading 8437; parts thereof: parts: of mowers for lawns, parks or sports grounds: wheel and tire
assemblies. The general rate of duty will be Free.
Note 1(k) to Section XVI excludes articles of Chapter 82, HTSUS from classification in Chapter 84, HTSUS.
The lawn mower blades are classified in Chapter 82, HTSUS. Accordingly, the applicable subheading for the
lawn mower blades will be 8208.40.3000, HTSUS, which provides for knives and cutting blades, for
machines or for mechanical appliances, and base metal parts thereof: for agricultural, horticultural or forestry
machines, and parts thereof: lawnmower blades. The general rate of duty will be free.
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 subheadings 8208.40.3000, 8433.11.0010, 8433.90.1010 and 8433.90.1090, 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. 9903.01.25, in addition to subheadings
8208.40.3000, 8433.11.0010, 8433.90.1010 and 8433.90.1090, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 8208.40.3000, 8433.90.1010 and 8433.90.1090, HTSUS, unless specifically excluded, are
subject to an 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 subheadings 8208.40.3000, 8433.90.1010 and
8433.90.1090, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8433.11.0010, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15,
in addition to subheading 8433.11.0010, 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 Anthony Grossi at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division