CLA-2-84:OT:RR:NC:N2:201
Fabio Ravazzi
GKN Sinter Metals Ltda.
Emancipacao 4500
Hortolândia, Sao Paulo 13186-542
Brazil
RE: The tariff classification of a cam phaser rotor from Brazil
Dear Mr. Ravazzi:
In your letter dated October 8, 2025, you requested a tariff classification ruling.
The article under consideration has been identified as a cam phaser rotor, part number F-558189.19-0061.
You state the application is for passenger vehicles, specifically the Stellantis HEMI engine. The function of
the article is to mechanically modulate the camshaft rotation for optimal valve timing. It integrates/works
exclusively with the camshaft.
In your request you suggest classification of the cam phaser rotor in subheading 8409.91, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for parts of piston engines or 8483.90, HTSUS,
which provides for parts suitable for use solely or principally with transmission shafts (including camshafts),
gears, and related mechanical systems. This office agrees it would fall under HTSUS subheading 8409.91,
HTSUS, which provides for other parts suitable for use solely or principally with spark-ignition internal
combustion piston engines (including rotary engines).
The applicable classification subheading for the cam phaser rotor, part number F-558189.19-0061, will be
8409.91.5085, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts suitable
for use solely or principally with the engines of heading 8407 or 8408: Other: Other: Other: Other.” The rate
of duty will be 2.5% ad valorem.
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 8409.91.5085, 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 6, 2025, Executive Order 14323 imposed additional duties on products from Brazil. At this
time, products of Brazil provided by heading 9903.01.77, except for products described in headings
9903.01.78 – 9903.01.83, will be subject to an additional ad valorem rate of duty of 40 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.,
9903.01.77, in addition to subheading 8409.91.5085, 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 Brazil 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. 9903.02.09, in addition to subheading
8409.91.5085, 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 Matthew Sullivan at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division