CLA-2-84:OT:RR:NC:N1:103
Edoardo Ottani
Eurofork S.p.A.
Via Roma 93
Roletto 10060
Italy
RE: The tariff classification of a telescopic fork from Italy
Dear Mr. Ottani:
In your letter dated September 8, 2025, you requested a tariff classification ruling.
The merchandise under consideration is referred to as a telescopic fork, model number SD180x65, and is
described as industrial handling equipment used in automated storage and retrieval systems or other
automated environments. It is used to load and unload goods and designed to be mounted on a “standardized
load carrier,” which can be a fixed base, shuttle vehicle, stacker crane, etc.
Its main components include a fixed body, a gear and chain transmission, an asynchronous gearmotor, and a
steel telescoping arm mechanism with synchronized prongs. The prongs extend and retract horizontally to
handle loads. The telescopic fork is available in single deep, double deep, and triple deep configurations,
which vary in overall reach.
The applicable subheading for the telescopic fork, model number SD180x65, will be 8428.90.0390,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other lifting, handling,
loading or unloading machinery (for example, elevators, escalators, conveyors, teleferics): Other machinery:
Other.” The general rate of duty will be free.
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., 9903.81.91, in addition to subheading 8428.90.0390, 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. For products covered by heading 9903.81.91 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., 9903.02.20, in addition to subheading 8428.90.0390, 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 Paul Huang at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division