CLA-2-87:OT:RR:NC:N2:206
David Hartnett
Nissin International Transport USA
900 Thorndale Ave
Elk Grove Village, IL 60007
RE: The tariff classification of brake hose fittings from Japan
Dear Mr. Hartnett:
In your letter dated August 18, 2025, you requested a tariff classification ruling, which was filed on behalf of
your client Konsei USA, Inc.
The articles under consideration are brake hose fittings, Part Numbers GH122-02340-F, GH122-05310-A,
and GH122-00800-A, which are used in passenger vehicles. The brake fittings are composed of cold forging
carbon steel and used specifically in braking systems of an automobile. You describe them as components of
a device that applies braking to the rotation of an automobile’s tire.
You suggested classifying the brake hose fittings in subheading 8708.30.5090, Harmonized Tariff Schedule
of the United States (HTSUS), which provides for parts of vehicle brakes. We agree.
In HQ 088393, dated March 26, 1991, CBP dealt with the difference between hose and pipe fittings. In that
ruling, CBP stated that, "[t]he question has arisen whether "hose fittings" are properly classifiable under the
provision for "tube or pipe fittings." The court in John V. Carr & Son, Inc. v. United States, 76 Cust.Ct. 162,
C.D. 4652 (1976), stated, “It is to be noted that a 'tube' as it is known within the industry is made of a single
extruded compound rather than many materials [which hoses are made of] and is never made on a flexible
nylon mandrel [such as the hose in John V. Carr].”"
Thus, hose fittings are classified according to their application, unlike “tube or pipe fittings.” Since the brake
hose fittings under consideration are used in braking systems of a vehicle, they are classified as parts of
braking systems.
The applicable subheading for the brake hose fittings, Part Numbers GH122-02340-F, GH122-05310-A, and
GH122-00800-A, will be 8708.30.5090, HTSUS, which provides for “Parts and accessories of the motor
vehicles of headings 8701 to 8705: Other parts and accessories of bodies (including cabs): Brakes and
servo-brakes; parts thereof: For other vehicles: 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
8708.30.5090, 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 Japan 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 8708.30.5090, 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