CLA-2-73:OT:RR:NC:N1:164
Dale Stuban
Vogelsang Fastener Solutions, Inc.
1790 Swarthmore Ave., Suite 1
Lakewood, NJ 08701
RE: The tariff classification of compression limiters from Germany
Dear Mr. Stuban:
In your letter dated September 2, 2025, you requested a tariff classification ruling regarding compression
limiters from Germany. Product information was submitted with your request.
The items under consideration are four models of “wrapped metal” steel compression limiters (Part Numbers
CL50-10480, CL50-10463, CL50-10456, CL50-10457). When plastic vehicle components are fastened to
other objects, the normal forces of screws and bolts in a tightened state can exceed the permissible surface
pressure of plastic, causing damage. Steel compression limiters are used to prevent such damage by providing
structural reinforcement around the cylindrical opening. Based on your submission, the compression limiters
will be imported as cylinders of various lengths with an open (split) seam running lengthwise from end to
end.
Additional qualities such as diameter, wall thickness, yield strength, edge design, recessing, shaping, and
corrosion protection are customizable upon request and may vary. According to your brochure, the
compression limiters are available in lengths of up to 80 millimeters and wall thicknesses of .5 to 3
millimeters. In follow-up correspondence, you clarified the compression limiters will be imported separately
to be assembled into finished automotive components after importation.
You suggested the compression limiters may be classified under subheading 7318.29.0000, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for Screws, bolts, nuts… and similar articles,
of iron or steel: Non-threaded articles: Other. We disagree. These compression limiters do not function like
the articles of this heading. Instead, they function to prevent the plastic component from cracking under
pressure.
Classification under the HTSUS is in accordance with the General Rules of Interpretation (GRIs). GRI 1
provides that the classification of goods will be determined according to the terms of the headings of the
tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely
on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2
through 6 will then be applied in order.
The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official
interpretation of the HTSUS. While not legally binding nor dispositive, the ENs provide a commentary on the
scope of each heading of the HTSUS and are generally indicative of the proper interpretation of these
headings. See T.D. 89-80, 54 Fed. Reg. 35127 (August 23, 1989).
Heading 7326, HTSUS, is a residual or basket provision which covers a wide range of iron or steel articles
that are not more specifically provided for elsewhere in the HTSUS. The ENs to heading 7326 state that
“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.” An article of iron or steel can
be classified in heading 7326 if it is determined that the item is not more specifically provided for in any
other heading of the tariff. Noting the compression limiters are not more specifically provided for in heading
7318 or any other heading of the tariff, they can be classified in heading 7326, HTSUS.
The applicable subheading for the compression limiters 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 the European
Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15
percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General
duty rate. 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
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