CLA-2-73:OT:RR:NC:N1:164
Moon Kyung-jin
JINSOL Customs Consulting & Logistic Service
129, Gaetbel-ro, Yeonsu-gu, Incheon
South Korea
RE: The tariff classification of gaskets from South Korea
Dear Moon Kyung-jin:
In your letter dated August 18, 2025, you requested a tariff classification ruling regarding gaskets from South
Korea on behalf of your client, Hyundai Mobis Co., Ltd. Technical information was submitted with your
request.
The items under consideration are described as nitrile butadiene rubber (NBR) coated stainless steel gaskets
which will be installed between an engine’s water pump and cylinder block to support stable engine
operation. As you described, the gaskets will be secured by bolts to fix and seal the joint surface between the
components to prevent coolant leakage, maintain cooling system pressure, and ensure airtight sealing
between the water pump and the cylinder block. The stainless steel gaskets are specifically shaped to the
water pump and cylinder block joint surfaces. Additionally, the half-bead NBR surface coating fills
microscopic gaps and provides uniform compression. The gaskets are .4 millimeters (mm) thick and measure
136.3 mm in length by 165.5 mm in width. Each gasket weighs 6 grams (5 grams stainless steel; 1 gram
NBR).
In your submission, you suggest that the gasket is classifiable under subheading 8484.10.0000, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for Gaskets and similar joints of metal
sheeting combined with other material or of two or more layers of metal; sets or assortments of gaskets and
similar joints, dissimilar in composition, put up in pouches, envelopes or similar packings; mechanical seals:
Gaskets and similar joints of metal sheeting combined with other material or of two or more layers of metal.
We disagree. The gaskets of heading 8484 must be constructed according to the conditions of the heading
language, which is further described in the Explanatory Notes (ENs).
The ENs to heading 8484 indicate that these are composed of:
(i) a core of asbestos (or sometimes felt, cardboard or other non-metallic material) sandwiched
between two metal sheets; or
(ii) asbestos or other non-metallic materials cut to shape, and with metal sheeting folded along the
outer edges and around the edges of any holes punched in the gasket or joint: or
(iii) layers or metal foil (of the same metal or of dissimilar metals) pressed together.
Based on the documents submitted, the subject gaskets consist of a single stainless-steel layer with a NBR
coating. As such, they do not meet the conditions of the heading and are precluded from heading 8484.
Heading 7326, HTSUS, provides for other articles of iron or steel. The ENs to heading 7326 state “This
heading covers all iron or steel articles obtained by forging or punching, by cutting or stamping or by other
processes such as folding, assembling, welding, turning, milling or perforating other than articles included in
the preceding headings of this Chapter or covered by Note 1 to Section XV or included in Chapter 82 or 83 or
more specifically covered elsewhere in the Nomenclature.” Since the gaskets are not more specifically
provided for in heading 8484, or any other heading of the tariff, the gaskets will be classified in heading
7326, HTSUS.
The applicable subheading for the gaskets will be 7326.90.8688, HTSUS, which provides for Other articles
of iron or steel: Other: Other: Other: Other: Other. The general rate of duty will be 2.9 percent ad valorem.
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter
99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as
products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 percent upon
the value of the steel content. At the time of entry, you must report the Chapter 99 heading applicable to your
product classification, i.e. 9903.81.90, in addition to subheading 7326.90.8688, HTSUS. Derivative iron or
steel products processed in another country from steel articles melted and poured in the United States,
provided for in heading 9903.81.92, are not subject to the additional ad valorem duties.
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. For products covered by heading
9903.81.90, this additional duty applies to the non-steel content of the merchandise. 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 7326.90.8688, 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
(C.F.R.), 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 C.F.R. 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 Taylor at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division