CLA-2-87:OT:RR:NC:N2:206

Gary Chen
Pan American Automotive Parts Trading LLC
600 Brents Rd
Lewisburg, TN 37091

RE: The tariff classification of vehicle door components from Mexico

Dear Mr. Chen:

In your letter dated September 10, 2025, you requested a tariff classification ruling.

The articles under consideration are various aluminum stampings used in the frame of a passenger vehicle door. The articles are described as follows:

BRKT-FR DR SASH RR - Part Number 80238-6SA0A-A is a vehicle door bracket used in the front door to strengthen the frame’s structure. You state that it is subsequently installed into the B-pillar cover and door lock. The bracket does not function as a joint and is made by a stamping process.

BRKT - RR DR SASH - Part Number 82238-6TA0A-A is a vehicle door bracket used in a rear door to strengthen the frame’s structure and to carry the door’s weight. It is made by a stamping process and does not serve a joining function.

CORNER PIECE FR DOOR INR - Part number 80230-6SA0A is a door corner piece used at the front door rearview mirror and injection molding triangular A-pillar cover. It is made by a stamping process and does not server a joining function.

REINF- FR DR INR WAIST - Part Number 80142-6SA0A is a vehicle door reinforcement used to enhance the front door frame structure and to form an installation platform for the outer water belt. It is made by a stamping process and does not have a joining function.

REINF- RR DR INR WAIST - Part Number 82142-6SA0A is a vehicle door reinforcement used to enhance the rear door frame structure and to form an installation platform for the outer water belt. It is made by a stamping process and doe not have a joining function. RR DR SASH - RR OTR - Part Number 82258-6SA0A is vehicle door sash used in the C-pillar position of the rear door to enhance the door frame structure. It is subsequently installed into the C-pillar cover and door lock. It is made by a stamping process and does not function as a joint.

The applicable subheading for the BRKT-FR DR SASH RR - Part Number 80238-6SA0A-A, BRKT - RR DR SASH - Part Number 82238-6TA0A-A, CORNER PIECE FR DOOR INR - Part number 80230-6SA0A, REINF- FR DR INR WAIST - Part Number 80142-6SA0A, REINF- RR DR INR WAIST - Part Number 82142-6SA0A, and RR DR SASH - RR OTR - Part Number 82258-6SA0A will be 8708.29.5110, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories of bodies (including cabs): Other: Other: Stampings.” The general rate of duty will be 2.5 percent ad valorem.

Effective May 3, 2025, Presidential proclamation 10908 imposed additional tariffs on certain automobile parts. Additional duties on automobile parts of 25 percent are reflected in Chapter 99, heading 9903.94.05, as provided in subdivision (g) of U.S. note 33 to this subchapter. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.94.05, in addition to subheading 8708.29.5110. 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 Mexico are not subject to reciprocal tariffs. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.27, in addition to subheading 8708.29.5110, 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/.

You also inquired about the classification of these articles if they undergo stamping, spot-welding, and ED-coating or hemming processes. Please note, Title 19, Code of Federal Regulations, Section 177.7(a) provides that “no ruling letter will be issued with regard to transactions or questions which are essentially hypothetical in nature or in any instance in which it appears contrary to the sound administration of the Customs and related laws to do so.” Since you did not provide any evidence of a prospective importation on the articles undergoing spot-welding and ED-coating or hemming, this office will not rule on this scenario.

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 Liana Alvarez at [email protected].
Sincerely,

(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division