CLA-2-84:OT:RR:NC:N1:102
Takayuki Hirano
Shima American Corporation
500 Park Blvd., Suite 760
Itasca, IL 60143
RE: The tariff classification of pulleys from China
Dear Mr. Hirano:
In your letter dated September 23, 2025, you requested a tariff classification ruling. Descriptive information
was provided with your submission.
The items at issue are steel pulleys, item numbers PN161-1031, PN161-1043 and PN161-1078. The grooved
pulleys are configured as wheels that transmit power using a belt system. The pulleys drive the rotation of
cutting or thrashing blades installed in commercial lawn mowers, which can be used for large acreage
mowing and pasture maintenance.
The applicable subheading for the steel pulleys will be 8483.50.9040, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for Transmission shafts (including camshafts and crankshafts) and
cranks; bearing housings, housed bearings and plain shaft bearings; gears and gearing; ball or roller screws;
gear boxes and other speed changers, including torque converters; flywheels and pulleys, including pulley
blocks; clutches and shaft couplings (including universal joints); parts thereof: Flywheels and pulleys,
including pulley blocks: Other: Other: Grooved pulleys. The general rate of duty will be 2.8 percent ad
valorem.
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 8483.50.9040, 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 8483.50.9040, 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 8483.50.9040, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8483.50.9040, 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 8483.50.9040, HTSUS, listed above.
Additionally, you requested that the pulleys be considered for duty-free treatment under subheading
9817.00.60, HTSUS. Section 177.7 of the Customs Regulations (19 C.F.R. §177.7) provides that rulings will
not be issued in certain circumstances. Specifically, Part 177.7(b) reads, in pertinent part: No ruling letter will
be issued with respect to any issue which is pending before the United States Court of International Trade,
the United States Court of Appeals for the Federal Circuit or any court of appeal. As such, CBP will not issue
a ruling regarding the eligibility of the pulleys under subheading 9817.00.60, HTSUS, at this time. The
classification determination may be impacted by court cases currently pending in the Court of International
Trade. See Great States Corporation DBA American Lawn Mower Co. v. United States, Court No. 24-00216;
Melnor Inc. v. United States, Court No. 25-00052; and Hydro Gear v. United States, Court No. 23-00044.
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 Sandra Martinez at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division