CLA-2-87:OT:RR:NC:N2:206
Moon Kyung-jin
JINSOL Customs Consulting & Logistic Service
129, Gaetbel-ro, Yeonsu-gu,
Incheon
South Korea
RE: The tariff classification of a license plate moulding from South Korea
Dear Mr. Kyung-jin:
In your letter dated August 18, 2025, you requested a tariff classification ruling, which you filed on behalf of
Hyundai Mobis Co., Ltd.
The article under consideration is Moulding-FRT BPR License Plate (Moulding), Part Number 86519T6010,
which is used in passenger vehicles. This component is mounted on the front bumper of a vehicle to secure
and support the license plate, forming the connection and mounting structure between the bumper and the
license plate. It also fills the gap between them, enhancing the aesthetic appearance. The Moulding is
constructed of a thermoplastic polyolefin (TPO) and measures 305mm in width, 153mm in height, and 42mm
in depth.
You suggest classifying the Moulding in subheading 3926.30.5000, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for “Other articles of plastics and articles of other materials of
headings 39.01 to 39.14; Fittings for furniture, coachwork, or the like.” To support your analysis, you cite
New York Rulings N340241, dated 07/11/2024, and N077777, dated 10/22/2009, and N012506, dated
07/10/2007. Furthermore, you highlight the Explanatory Note in Section XVII excluding, in pertinent parts,
“mountings for vehicle coachwork…, number plates, nationality plates…” from this Section.
We disagree with your analysis. The cited rulings describe articles that are different in function and use from
the Moulding at issue. Furthermore, the Moulding is neither a mounting, nor a number or nationality plate. It
is a license plate bracket. Explanatory Note 8708 lists such brackets as parts and accessories of vehicle
bodies. It states, “Parts of bodies and associated accessories, for example, floor boards, sides, front or rear
panels, luggage compartments, etc.; doors and parts thereof; bonnets (hoods); framed windows, windows
equipped with heating resistors and electrical connectors, window frames; runningboards; wings (fenders),
mudguards; dashboards; radiator cowlings; numberplate brackets…” As a result, classification of the
Moulding in subheading 3926.30.5000, HTSUS, is precluded.
The applicable subheading for the Moulding-FRT BPR License Plate (Moulding), Part Number 86519T6010,
will be 8708.29.5160, HTSUS, which provides for “Parts and accessories of the motor vehicles of headings
8701 to 8705: Other parts and accessories of bodies (including cabs): Other: Other: Other.” The rate of duty
will be 2.5 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
8708.29.5160, 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 8708.29.5160, 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 Liana Alvarez at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division