CLA-2-73:OT:RR:NC:N1:164
Eduardo Garcia De La Cadena
K Line Logistics USA
308 Heritage Club Circle
Atlanta, GA 30132
RE: The tariff classification of springs from Japan
Dear Mr. Garcia De La Cadena:
In your letter dated August 22, 2025, you requested a tariff classification ruling regarding springs from Japan
on behalf of your client, NHK Spring Precision of America Inc. Technical information was submitted with
your request.
The items under consideration are four models of helical oil tempered steel springs which will be used in
automotive applications.
The first items are Valve Springs which will be used to control the opening and closing of intake and exhaust
valves in automotive engines. The Valve Springs measure 2.7 millimeters (mm) in round cross-sectional wire
diameter, 19.8 mm in outer diameter, 40.62 mm in free length, and have a maximum load of 357.9 newtons
(N).
The second items are Damper Springs (Straight Type) which will be used for vibration and torque fluctuation
absorption in the lock-up clutch system of automotive engines. The cross-sectional wire shape is oval and
measures 2.3 by 2.88 mm in diameter. The coils are aligned in a straight shape and measure 19.1 mm in outer
diameter, 42 mm in free length, and have a maximum load of 331.9N.
The third items are Damper Springs (Arc Type) which will also be used for vibration and torque fluctuation
absorption in the lock-up clutch system of automative engines. The cross-sectional wire shape is oval and
measures 3 by 3.75 mm in diameter. The coils are set in an “arc” shape and measure 18.3 mm in outer
diameter, 136.45 mm in free length, and have a maximum load of 759.1N.
The fourth items are Clutch Piston Return Springs which will be used for pressure application and as a return
mechanism in automotive transmission clutch systems. The Clutch Piston Return Springs measure 6.8 mm in
round cross-sectional wire diameter, 76.8 mm in outer diameter, 56.8 mm in free length, and have a
maximum load of 1,559N. You state that all four models receive surface treatment including nitriding, shot
peening, and coating with anti-rust oil.
In your request, you suggest classification of the springs in headings 8409 or 8708, Harmonized Tariff
Schedule of the United States (HTSUS). Heading 8409, HTSUS, provides for “Parts suitable for use solely or
principally with the engines of heading 8407 or 8408.” Heading 8708, HTSUS, provides for “Parts and
accessories of the motor vehicles of heading 8701 to 8705.” We disagree.
Classification of merchandise under the HTSUS is governed by the General Rules of Interpretation (GRIs).
GRI 1 provides that classification is determined first in accordance with the terms of the headings of the tariff
and any relative section or chapter notes. Note 1(g) to Section XVI and Note 2(b) to Section XVII exclude
“Parts of general use as defined in note 2 to section XV, of base metal (section XV) or similar goods of
plastics (chapter 39).” Note 2(b) to Section XV lists springs and leaves for springs, of base metal, as parts of
general use. Since the articles under consideration are springs, classification of the items in heading 8409 of
Section XVI and heading 8708 of Section XVII is precluded.
The applicable subheading for the Valve Springs, Damper Springs (Straight Type), and Damper Springs (Arc
Type) will be 7320.20.5020, HTSUS, which provides for Springs and leaves for springs, of iron or steel:
Helical Springs: Other: Helical springs, of wire having a cross-sectional dimension of less than 5.1 mm:
Other. The general rate of duty will be 3.9 percent ad valorem.
The applicable subheading for the Clutch Piston Return Springs will be 7320.20.5045, HTSUS, which
provides for Springs and leaves for springs, of iron or steel: Helical Springs: Other: Helical springs, of wire
having a cross-sectional dimension of 5.1 mm or more but less than 12.7 mm. The general rate of duty will be
3.9 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 subheadings 7320.20.5020 and 7320.20.5045, 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 Japan will be
subject to an additional ad valorem rate of duty of 15 percent. Your products fall 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 subheadings 7320.20.5020 and 7320.20.5045, 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