CLA-2-82:OT:RR:NC:N:1:118
Tina Richards
A.N. Deringer, Inc.
173 W Service Rd.
Champlain, NY 12919
RE: The tariff classification of a saw tooth and a mulcher tooth from Canada
Dear Ms. Richards:
In your letter dated July 16, 2025, you requested a tariff classification ruling on behalf of your client, Quadco
Group, Inc.
The two items under consideration are identified as a beaver style saw tooth (item number Q10233T) and a
planer style mulcher tooth (item number QMX10380T). Both teeth are made of heat-treated high strength
steel and incorporate irregularly shaped cutting tips and blades with threaded center holes for mounting. You
have stated that each tooth will be imported unmounted.
The beaver style saw tooth is used on a felling head equipped with a saw disc. The tooth is attached to the
saw disc by means of a 1-inch bolt. The felling head is attached to a feller buncher, which cuts down trees
and arranges them into piles. The planer style mulcher tooth is used on an excavator or a feller buncher that
is equipped with a mulching head. The mulching head is comprised of a rotating mulching drum and the
planer style mulching tooth is attached to the drum by means of a 1-inch bolt. The mulching head is used to
grind and shred tree trunks and/or entire trees depending on their size.
The applicable subheading for the beaver style saw tooth (item number Q10233T) and the planer style
mulcher tooth (item number QMX10380T) will be 8208.40.6000, Harmonized Tariff Schedule of the United
States (HTSUS), which provides for knives and cutting blades, for machines or mechanical appliances, and
base metal parts thereof: for agricultural, horticultural, or forestry machines, and parts thereof: other. The
general rate of duty will be free.
Products of Canada as provided by heading 9903.01.10 in Section XXII, Chapter 99, Subchapter III, U.S.
Note 2(j), HTSUS, other than products classifiable under headings 9903.01.11, 9903.01.12, 9903.01.13,
9903.01.14, and 9903.01.15, HTSUS, will be subject to an additional 25 percent ad valorem rate of duty. At
the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.10, in addition to
subheading 8208.40.6000, HTSUS, listed above. Articles that are entered free of duty under the terms of
general note 11 to the HTSUS (U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set
forth in subchapter XXIII of Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be
subject to the additional ad valorem duties provided for in heading 9903.01.10. If your product is entered
duty free as originating under the USMCA, you must report heading 9903.01.14, HTSUS, in addition to
subheading 8208.40.6000, HTSUS.
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. Your products fall within an excepted
subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.01.26, in addition to subheading 8208.40.6000, 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