CLA-2-84:OT:RR:NC:N1:104
Maria Bush
Continental Tire the Americas, LLC
1794 MacMillan Park Drive
Fort Mill, SC 29707
RE: The tariff classification of tread cassette carts from Czech Republic
Dear Ms. Bush:
In your letter dated October 10, 2025, you requested a tariff classification ruling.
The item in question is a Tread Cart, Width ID 50500027, also referred to as a tread cassette cart. The tread
cassette cart consists of two rotating steel drums resembling spools that are permanently mounted on a steel
wheeled frame. The purpose and function of the tread cassette cart is to store and transport rubber tread and
other tire building materials that will be used in a tire-building machine (TBM). The drums possess certain
mechanical features including clutches that aid in winding the tire building material onto the drums, and a
brake to prevent the material from unspooling during transport. When the materials are needed, the tread
cassette cart is transported to the TBM’s let-off station where the materials are unspooled and used in tire
production. The tread cassette cart will not be imported with rubber tread or any other material.
You ask whether the tread cassette cart may be considered a part of a machine for working rubber under
subheading 8477.90.8695, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. It is not
an integral, component part of a TBM. Rather, the tread cassette cart is a mechanical device used to store and
then transport the tire building materials to the TBM when needed.
The applicable subheading for the Tread Cart, Width ID 50500027, will be 8479.89.9599, HTSUS, which
provides for “Machines and mechanical appliances having individual functions, not specified or included
elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other: Other: Other.”
The general rate of duty will be 2.5%.
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 the European
Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15
percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General
duty rate. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.02.20, in addition to subheading 8479.89.9599, 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 Arthur Purcell at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division