CLA-2-84:OT:RR:NC:N1:104
Matthew Aldridge
National Air Cargo
350 Windward Dr
Orchard Park, NY 14127
RE: The tariff classification of strut spring compressors from Germany
Dear Mr. Aldridge:
In your letter dated September 9, 2025, on behalf of your client, Geodore Tools, Inc., you requested a tariff
classification ruling.
The products at issue are two strut spring compressors, models KL-5501 and KL-5901, which are stationary
systems used to remove struts, springs, and shock absorbers from vehicles. This is accomplished by
compressing the strut assembly’s coil spring, allowing the strut to be repaired or replaced. The two systems
are similar in function and design, with KL-5501 used for softer strut springs, while the KL-5901 is a heavier
duty model used to compress harder strut springs. The KL-5501 is generally mounted on a stable surface
such as a large tool box or a wall, while the KL-5901 has a base with legs, making it self-supporting.
The KL-5501 and the KL-5901 are comprised of various components including a spring compressor unit, an
upper spring plate holder with adjustable jaws, lower arm/plate and other supports, devices for securing and
holding the strut assembly, a lower adaptor (for the KL-5901), and handles or wrenches for adjusting the
securing mechanisms. In operation, the user places the entire strut assembly into the spring compressor unit
and secures it in place. The user then positions the jaws symmetrically on the upper spring plate. Next, the
user manually rotates a drive nut at the top of the machine using either a manual ratchet or a hand crank for
the KL-5501, or a turnstile-type handle for the KL-5901; this applies downward pressure on the jaws,
compressing the spring between the upper and lower spring plates. The compression creates clearance to
allow the strut to be disassembled from its top mount. The KL-5501 and KL-5901 are hand-operated only; no
hydraulics are employed in either of these models.
According to your submission, the spring compressor will be complete upon arrival in the U.S. in one
shipment, but may be partially disassembled. General Rule of Interpretation 2(a), Harmonized Tariff
Schedule of the United States (HTSUS), states, inter alia, that any reference in a heading to an article
includes an article which is complete but entered unassembled or disassembled.
The applicable subheading for the Geodore spring compressors, models KL-5501 and KL-5901, will be
8479.89.9599, HTSUS, which provides for “Machines and mechanical appliances having individual
functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical
appliances: Other: Other: Other.” The general rate of duty will be 2.5 percent ad valorem.
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. 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 8479.89.9599, 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 Arthur Purcell at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division