CLA-2-87:OT:RR:NC:N2:201
Jill Cramer
Mowry & Grimson, PLLC
5335 Wisconsin Ave., NW, Suite 810
Washington, DC 20015
RE: The tariff classification of landing gear parts for the front of a fifth wheel and commercial trailer from
Canada
Dear Ms. Cramer:
In your letter dated July 18, 2025, you requested a tariff classification determination on behalf of your client,
Nova Steel Inc., located in La Salle, Canada. Several pictures, illustrations, and exhibits were provided with
your request.
The articles under consideration have been identified as the driven legs, specialized landing gear parts, used
on trailers classified in heading 8716 of the Harmonized Tariff Schedule of the United States (HTSUS). The
driven leg landing gear parts are square, hot rolled, pickled and oiled steel tubes. You state that, in Canada,
the driven leg landing gear parts are cut to-length, manufactured to specific customer tolerances, and laser-cut
with holes. You further state that these parts do not undergo any further processing in the United States,
thereby, making the driven leg landing gear parts ready for assembly upon importation and use in the trailer
chassis.
The landing gears are permanently attached to the underside of trailers. Landing gears are used to lift and
stabilize a vehicular trailer so that it may be disengaged from the fifth wheel of a tractor. The driven legs are
integral parts of the landing gear legs, forming the structural integrity of the legs of the gears, without which
the landing gear could not function. Landing gears are comprised of both a left and right leg and are
typically installed at the front of a vehicular trailer. The left and right legs of the landing gear require five (5)
separate sub-assemblies that are required for the landing gear’s functionality: the driving leg assembly;
driven leg assembly; foot assembly; crank assembly and connection shaft.
You indicate these parts will be used in your client’s landing gear product line, listed below.
1. A400 - Static Load Capacity 160,000 lbs.
2. A440 - Static Load Capacity 170,000 lbs.
3. A450 - Static Load Capacity 170,000 lbs.
4. H450 - Static Load Capacity 200,000 lbs.
5. UL500 - Static Load Capacity 160,000 lbs.
6. AX100 - Static Load Capacity 160,000 lbs.
The applicable subheading for landing gear parts for the front of a fifth wheel and commercial trailer will be
8716.90.5060, HTSUS, which provides for “Trailers and semi-trailers; other vehicles, not mechanically
propelled; and parts thereof: Parts: Other: Other.” The rate of duty will be 3.1 percent ad valorem.
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
8716.90.5060, HTSUS, listed above. Articles 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 are not parts of passenger vehicles (sedans, sport utility vehicles, crossover vehicles, minivans or cargo
vans) and light trucks, will not be subject to the additional ad valorem duties provided for in heading
9903.94.05. If your product is entered duty free as originating under the USMCA, you must report heading
9903.94.06, HTSUS, in addition to subheading 8716.90.5060, 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 of Canada are not
subject to reciprocal tariffs. 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 8716.90.5060, 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 Matthew Sullivan at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division