CLA-2-84:OT:RR:NC:N1:103
9903.88.01
Ashley Ahrens
Noatum Logistics
20 N Martingale Rd., Suite 200
Schaumburg, IL 60173
RE: The tariff classification of a loader frame from India and a mower attachment from China
Dear Ms. Ahrens:
In your letter dated September 9, 2025, you requested a tariff classification ruling on behalf of your client,
Mahindra USA.
The first group of items under consideration are referred to as front-end loader attachments for tractors, part
numbers MLA1100L, MLA2100L, MLA1626LR, MLA1635LR, MLA1640LR, MLH45504L,
MLMX5155L, and MLTEC60754L, imported from India. The loader attachments are optional and
detachable equipment that give a tractor the ability to lift and move materials. Each loader attachment
consists of a metal boom assembly with parallel arms and pivoting sections, which are operated by actuator
assemblies powered by the hydraulic system of the tractor. Each loader will be imported with a
general-purpose shovel bucket that can be used to load and unload materials.
The applicable subheading for the front-end loader attachment and bucket, when imported in equal quantities,
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 August 27, 2025, Executive Order 14339 imposed additional duties on products from India. At this
time, products of India provided by heading 9903.01.84, except for products described in headings
9903.01.85 – 9903.01.89, will be subject to an additional ad valorem rate of duty of 25 percent. 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.,
9903.01.84, in addition to subheading 8428.90.0390, 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 India will be
subject to an additional ad valorem rate of duty of 25 percent. 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., 9903.02.26, in addition to subheading
8428.90.0390, HTSUS, listed above.
The second group of items under consideration, part numbers MQ1154, MQ1160 and MQ2160, are described
as mid-mount mowers imported from China. These mowers function with their cutting blades operating in a
horizontal plane and are powered by the power take off (PTO) of a tractor. They are mounted to the bottom
of a tractor via a bracket linkage system that moves with the mower when it is raised and lowered.
Advertising and marketing materials for the mowers indicate that they are used for landscaping and other
gardening needs. You have stated that they will be imported as complete unassembled kits containing both
the mower assembly and mounting equipment.
You suggested classifying the mid-mount mowers within subheading 8428.90.0390, HTSUS, which provides
for other lifting, handling, loading or unloading machinery (for example, elevators, escalators, conveyors,
teleferics): other machinery: other. We disagree. Classification of merchandise under the HTSUS is governed
by the General Rules of Interpretation (GRIs) taken in order. GRI 1 provides that classification is determined
first in accordance with the terms of the headings and any relative section and chapter notes. The mid-mount
mowers under consideration are specifically provided for in a different tariff heading than your proposed
classification.
The applicable subheading for the mid-mount mowers, part numbers MQ1154, MQ1160 and MQ2160, will
be 8433.20.0020, HTSUS, which provides for “harvesting or threshing machinery, including straw or fodder
balers; grass or hay mowers; machines for cleaning, sorting or grading eggs, fruit or other agricultural
produce, other than machinery of heading 8437; parts thereof: other mowers, including cutter bars for tractor
mounting…tractor drawn or for tractor mounting: rotary cutter type.” The general rate of duty will be free.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e., 9903.01.24, in addition
to subheading 8433.20.0020, HTSUS, listed above.
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 8433.20.0020, 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 China, Hong
Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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., 9903.01.25, in
addition to subheading 8433.20.0020, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8433.20.0020, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01,
in addition to subheading 8433.20.0020, 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
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division