CLA-2-39:OT:RR:NC:N5:137
Felix Zhang
MAXFORCE TOOLS (CAMBODIA) CO., LTD.
Building D61-4, Sihanoukville Special Economic Zone
Sihanoukville 180100
Cambodia
RE: The tariff classification of air hose reels from Cambodia
Dear Mr. Zhang:
In your letter dated July 14, 2025, you requested a tariff classification ruling.
SKU#: 821-1360 is a 50-foot single arm retractable air hose reel. It consists of a ½ inch by 50-foot air hose
and a reel. The reel is made of steel and includes a spring-loaded auto-rewind reel mechanism, while the hose
is constructed predominantly of polyvinyl chloride (PVC) plastic reinforced with braided polyester and
features male brass fittings at both ends.
The hoses serve to deliver pressurized air from an air compressor to pneumatic hand tools while the reels,
which can be mounted to a wall or ceiling, provide storage for the hose. Like the hose and reel combinations
ruled upon in New York Ruling Letters N217149 and N271823, dated June 7, 2012, and February 2, 2016,
respectively, the essential character of the air hose reels at issue is imparted by the hoses.
The applicable subheading for the air hose reels will be 3917.39.0020, HTSUS, which provides for tubes,
pipes and hoses and fittings therefor (for example, joints, elbows, flanges), of plastics: other tubes pipes and
hoses: other: other: of polyvinyl chloride. The general rate of duty will be 3.1% ad valorem.
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 Cambodia, 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 3917.39.0020, 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 Christina Allen at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division