CLA-2-40:OT:RR:NC:N5:137
Richard Rice
Samoa Corporation
90 Monticello Rd
Weaverville, NC 28787
RE: The tariff classification of oil hose reels from China
Dear Mr. Rice:
In your letter dated July 24, 2025, you requested a tariff classification ruling.
The product under consideration is an oil hose reel. It consists of an oil hose and a reel. The reel is made of
steel, while the hose is constructed acrylonitrile-butadiene rubber (NBR) reinforced with braided steel wire
and features fittings composed of zinc plated steel.
The hose reels are used in garages, auto shops and construction sites. The hose delivers the oil while the
reels, which can be mounted, provide storage for the hose. Like the hose and reel combinations ruled upon in
New York Ruling Letters N217149 and N271823, dated June 7, 2012, and February 2, 2016, respectively, the
essential character of the oil hose reels at issue is imparted by the hoses.
You suggest classification of the oil hose reel in 3917.39.0050, Harmonized Tariff Schedule of the United
States (HTSUS). We disagree. The oil hose is composed of NBR which is a type of vulcanized rubber
provided for in Chapter 40, HTSUS. Therefore, the instant product is precluded from classification in
Chapter 39, HTSUS.
The applicable subheading for the oil hose reel will be 4009.22.0050, HTSUS, which provides for tubes,
pipes and hoses, of vulcanized rubber other than hard rubber, with or without their fittings (for example,
joints, elbows, flanges): reinforced or otherwise combined only with metal: with fittings: other. The general
rate of duty will be 2.5% ad valorem.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 4009.22.0050, 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,
including China, 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 4009.22.0050, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 4009.22.0050, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03,
in addition to subheading 4009.22.0050, 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 Christina Allen at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division