CLA-2-40:OT:RR:NC:N5:137
Moon Kyung-jin
JINSOL Customs Consulting & Logistic Service
129, Gaetbeol-ro, Yeonsu-gu
Incheon
South Korea
RE: The tariff classification of an ethylene propylene diene monomer (EPDM) rubber gasket assembly from
South Korea
Dear Mr. Kyung-jin:
In your letter dated August 11, 2025, you requested a tariff classification ruling on behalf of your client
Dong-A Hwa Sung Co., Ltd.
Item number GI375-28000, is a gasket assembly seated at the outermost edge of the vehicle chassis between
the upper and lower cases of the electric vehicle battery. It serves to seal the interior against foreign
substances and moisture that may enter from outside the battery providing an air and water tight seal. It is
composed ethylene propylene diene monomer (EPDM) rubber that is perforated at regular intervals with
small steel rings in the holes for connection.
Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is in
accordance with the General Rules of Interpretation (GRIs). GRI 3(b) provides that mixtures, composite
goods consisting of different materials or made up of different components, and goods put up in sets for retail
sale shall be classified as if they consisted of the material or component which gives them their essential
character, which may be determined by the nature of the material or component, its bulk, quantity, weight or
value, or by the role of a constituent material in relation to the use of the article. We find that the gasket
assembly is a composite good. The gasket forms a seal around the battery to prevent foreign substances and
moisture from entering. The essential character is imparted by the EPDM rubber component.
The applicable subheading for the EPDM gasket assembly will be 4016.93.1050, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for other articles of vulcanized rubber other than
hard rubber: other: gaskets, washers and other seals: of a kind used in the automotive goods of chapter 87:
other. The general rate of duty will be 2.5 percent ad valorem.
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. At the time of entry, you must report
the Chapter 99 heading applicable to your product classification, i.e. 9903.02.56, in addition to subheading
4016.93.1050, 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