CLA-2-85:OT:RR:NC:N1:103
Jong Wook Kim
Unione Customs Clearance & Consulting Firm
18, Hakdong-ro 31-gil, Gangnam-gu
Seoul
South Korea
RE: The tariff classification of a frame component from South Korea
Dear Mr. Kim:
In your letter dated July 23, 2025, you requested a tariff classification ruling on behalf of your client,
Donghee Ind., Co., Ltd.
The merchandise under consideration is an internal support element, part number BL410-GI900-B, that is
used inside an electric vehicle battery assembly. It is described as an aluminum extrusion measuring
approximately 1,775 millimeters in length, 167.5 millimeters in width, and 100.7 millimeters in thickness.
The element is mounted in the center of the battery assembly and has three pre-cut notches along its length,
which serve as spaces for crossmember supports and additional structural frame components.
The applicable subheading for the structural component, part number BL410-GI900-B, will be 8507.90.8000,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric storage batteries,
including separators therefor, whether or not rectangular (including square); parts thereof: Parts: Other.” The
general rate of duty will be 3.4 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
8507.90.8000, 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 South Korea will
be subject to an additional ad valorem rate of duty of 15 percent. 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 8507.90.8000, HTSUS, listed above.
The merchandise in question may be subject to antidumping duties and countervailing duties (AD/CVD).
Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and Compliance
office in the International Trade Administration of the Department of Commerce and are separate from tariff
classification and origin rulings issued by Customs and Border Protection (CBP). You can contact them at
https://trade.gov/enforcement/ (click on “Contact Us”). For your information, you can view a list of current
AD/CVD cases at the United States International Trade Commission website at
https://www.usitc.gov/trade_remedy/documents/orders.xls, and you can search AD/CVD deposit and
liquidation messages using CBP’s AD/CVD Search tool at https://aceservices.cbp.dhs.gov/adcvdweb.
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 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 Paul Huang at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division