CLA-2-87:OT:RR:NC:N2:201
Isaac Mendiola
Mendiola Customs Brokerage
2112 S. Shary Rd, Suite 4
Mission, TX 78572
RE: The tariff classification of a 1999 Subaru Sambar light truck from Japan
Dear Mr. Mendiola:
In your letter dated July 23, 2025, you requested a tariff classification ruling.
The item under consideration has been identified as a 1999 Subaru Sambar, a light-duty utility vehicle. The
vehicle possesses the following features:
658cc (0.66 L) spark-ignition, internal combustion piston engine
“Cab-over" chassis with a driver's cab
Open rear cargo bed
Gross Vehicle Weight Rating (GVWR): Approximately 1,200 kg (1.2 metric tons)
Age: Over 25 years old
In your request you suggest classification of the vehicle in 8704.31.0120, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for "Motor vehicles for the transport of goods: Other, with only
spark-ignition internal combustion piston engine: G.V.W. not exceeding 5 metric tons: G.V.W. not exceeding
2.5 metric tons.” We concur.
The applicable subheading for the 1999 Subaru Sambar will be 8704.31.0120, HTSUS, which provides for
"Motor vehicles for the transport of goods: Other, with only spark-ignition internal combustion piston engine:
G.V.W. not exceeding 5 metric tons: G.V.W. not exceeding 2.5 metric tons.”. The general rate of duty will be
25% ad valorem.
Effective April 3, 2025, Presidential proclamation 10908 imposed additional tariffs on certain automobiles.
Additional duties on passenger vehicles (sedans, sport utility vehicles, crossover vehicles, minivans or cargo
vans) and light trucks of 25 percent, as provided in subdivision (b) of U.S. note 33 to this subchapter are
reflected in Chapter 99, heading 9903.94.01. Certain passenger vehicles and light trucks manufactured in a
year at least 25 years prior to the year of the date of entry, provided in heading 9903.94.04, are not subject to
the additional duties. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.94.04, in addition to subheading 8704.31.0120, 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 subheading
8704.31.0120, 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