CLA-2-40:OT:RR:NC:N2:201
Claire Brisiel
Assembled Products Corporation
405 W Easy St
Rogers, AR 72756
RE: The tariff classification of solid tires from China
Dear Ms. Brisiel:
In your letter dated September 30, 2025, you requested a tariff classification ruling.
The item under consideration are solid tires, part number 280-1346, stated as being made of Ethylene
Propylene Diene Monomer rubber (EPDM), which is a synthetic form of rubber. These solid tires are
designed for use with the “MartCart,” an electric shopping cart.
You state that these tires were designed with specific size, tread, load, and rolling resistance to meet specific
performance and safety requirements for use in indoor retail environments, and that they are not marketed
for, nor suitable for, bicycles, scooters, or passenger vehicles.
The applicable subheading for the solid tires, part number 280-1346, will be 4012.90.1000, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for “Retreaded or used pneumatic tires of
rubber; solid or cushion tires, tire treads and tire flaps, of rubber: Other: Solid or cushion tires”. 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 4012.90.1000, 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 China, Hong
Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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 4012.90.1000, HTSUS, listed above.
Pursuant to U.S. Note 31 (b) to Subchapter III, Chapter 99, HTSUS, effective September 27, 2024, products
of China classified under subheading 4012.90.1000, 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., 9903.88.03, in addition to subheading 4011.90.1000, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively.
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 Matthew Sullivan at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division