CLA-2-84:OT:RR:NC:N1:103
Timothy Ruland
The Gleason Works
1000 University Ave.
Rochester, NY 14607
RE: The tariff classification of a quench press from India
Dear Mr. Ruland:
In your letter dated September 12, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified as the Gleason 685Q Bevel Quenching Machine and is
described as a machine that uses a quenching process to finish bevel gears. The quenching machine has a
framed enclosure with sliding doors, access panels, and a main operator pendant. Its main components
include a programmable logic controller, a quenching oil system, and a hydraulic system. The hydraulic
system controls the flow of quenching oil and operates various components, including a lower die slide and
upper die slide that clamp the workpiece in place. Additional tools, such as spacers, pressure rings,
expanders, support rings, etc., can be added to the slides. Together, the die, the quenching chamber, and the
tools control and prevent any distortion to the workpiece as it is cooled.
The workpiece is cooled by the quenching system using controlled cycles and custom parameters like
temperature, timing, flow rate, and pressure. A typical cycle begins with placing the workpiece in the lower
die slide, which then retracts into the quenching chamber. Next, the upper die slide fully lowers to lock the
workpiece in place, and the quenching cycle begins. When the quenching cycle is complete, the upper die
slide raises so that a worker can remove and inspect the workpiece.
In your request, you suggest that the machine is classifiable in subheading 8461.40.5050, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for “Machine tools for planing, shaping, slotting,
broaching, gear cutting, gear grinding or gear finishing, sawing, cutting-off and other machine tools working
by removing metal or cermets, not elsewhere specified or included: Gear cutting, gear grinding or gear
finishing machines: Gear grinding or finishing machines: Other: For bevel gears.” We disagree.
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).
The ENs to heading 8461 state “the heading covers machine-tools working by removing metal or cermets,
not elsewhere specified or included.” Of particular relevance to your proposed classification as gear grinding
or finishing machines, the ENs clarify that heading 8461 “covers gear-cutting machines designed exclusively
for making gears by removing metal from cylindrical or conical blanks.” The exemplars list the following
processes: module-controlled milling-cutting; reproduction cutting which produces teeth by a planing tool;
cutting by meshing using a tool such as a worm hob, a rack cutting tool, or a pinion tool; and abrasive
cutting.
As described, the bevel gear quenching machine is neither designed for nor capable of performing the
machining operations noted in the ENs to heading 8461. During operation, there is no metal removal.
Furthermore, the force transmitted through the press does not shape the workpiece but provides stability,
prevents deformation, and maintains the precise gear shapes while the quenching process occurs. As a result,
classification in heading 8461, HTSUS, is precluded.
The applicable subheading for the Gleason 685Q Bevel Quenching Machine will be 8419.89.9540, HTSUS,
which provides for “Machinery, plant or laboratory equipment, whether or not electrically heated (excluding
furnaces, ovens and other equipment of heading 8514), for the treatment of materials by a process involving a
change of temperature such as heating, cooking, roasting, distilling, rectifying, sterilizing, pasteurizing,
steaming, drying, evaporating, vaporizing, condensing or cooling, other than machinery or plant of a kind
used for domestic purposes; instantaneous or storage water heaters, nonelectric; parts thereof: Other
machinery, plant or equipment: Other: Other: Other: Designed for cooling: Other.” The general rate of duty
will be 4.2 percent ad valorem.
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. 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 8419.89.9540, 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. 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
8419.89.9540, 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