CLA-2-84:OT:RR:NC:N1:105
Renee Sanford
Techemet LP
6025 Genoa Red Bluff Road
Pasadena, TX 77507
RE: The tariff classification of catalytic converters from various countries
Dear Ms. Sanford:
In your letter dated July 18, 2025, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The items under consideration are described as used catalytic converters, which are devices in a vehicle’s
exhaust system that reduce harmful emissions from being released into the atmosphere. They work by
converting pollutants like carbon monoxide, hydrocarbons, and nitrogen oxides into less harmful substances
like carbon dioxide, water, and nitrogen. This conversion is achieved through chemical reactions facilitated
by catalytic materials, usually platinum, palladium, and rhodium.
The catalytic converters being imported are used and are said to be imported to extract the platinum,
palladium, rhodium, and rare earth elements through a process that includes mechanical de-canning, chemical
assays, metallurgical separation, and refining. In our opinion, this process does not change the fact that the
catalytic converters are imported complete with all of the components necessary to be classified as a catalytic
converter.
Accordingly, the applicable subheading for the used catalytic converters will be 8421.32.0000, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for “Centrifuges, including centrifugal dryers;
filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying
machinery and apparatus for gases: Catalytic converters or particulate filters, whether or not combined, for
purifying or filtering exhaust gases from internal combustion engines.” The general rate of duty will be free.
Effective May 3, 2025, Presidential proclamation 10908 imposed additional tariffs on certain automobile
parts. Additional duties on automobile parts of 25 percent are reflected in Chapter 99, heading 9903.94.05, as
provided in subdivision (g) of U.S. note 33 to this subchapter. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.94.05, in addition to subheading
8421.32.0000, 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. Your product falls within an excepted
subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.01.33, in addition to subheading 8421.32.0000, HTSUS, listed above.
In your letter, you suggest that the used catalytic converters may be subject to 9903.94.06, HTSUS, which
states: Effective with respect to entries on or after May 3, 2025, articles provided for in subdivision (h) of
U.S. note 33 to this subchapter.
Subdivision (h) states:
Heading 9903.94.06 applies to all entries of articles classifiable under provisions of the HTSUS enumerated
subdivision (g) of this note:
(i) that are eligible for special tariff treatment under the United States-Mexico-Canada Agreement
(USMCA), other than automobile knock-down kits or parts compilations; or
(ii) that are not parts of passenger vehicles (sedans, sport utility vehicles, crossover utility vehicles,
minivans, and cargo vans) and light trucks.
No additional information was provided to support applicability under the USMCA, therefore, (i) is not
satisfied. The catalytic converters are also clearly intended for use with passenger vehicles and light trucks,
therefore, (ii) is not satisfied. Consequently, heading 9903.94.06 will not be applicable to the used catalytic
converters subject to this ruling.
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 Jason Christie at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division