CLA-2-82:OT:RR:NC:N1:118
Bae Taeho
Hyundai Motor Company
231, Yangjae-dong, Seocho-gu
Seoul 06797
South Korea
RE: The tariff classification of stamping dies from South Korea
Dear Mr. Taeho:
In your letter dated October 20, 2025, you requested a tariff classification ruling.
The items under consideration are five dies that operate individually within a production line that produces
automotive body components from steel or aluminum sheets. Each die consists of an upper and lower
component and is made primarily of cast iron. The dies are mounted on the upper and lower sections of press
equipment that performs a repetitive vertical motion. Pressure from both the upper and lower component is
then applied to the steel or aluminum sheets. You have stated that because of the large size of the dies, each
complete die (i.e., the upper and lower component) will be imported separately. The dies are identified and
described as follows:
Drawing Die (OP10) – Designed to form blank metal sheets into pre-defined automotive body panel
shapes by applying pressure to both upper and lower surfaces.
Trimming Die (OP20) – Used to trim excess material and pierce mounting holes for automotive body
part assembly.
Flanging Die (OP30) – Used to bend designated sections (flanging) for automotive body panel
production.
Restriking Die (OP40) – Re-forms areas requiring further shaping (restriking) for automotive body
panel production.
Hemming Die (HEM) – Used to bend and press the edges of outer body panels for accurate joining
with inner panels.
You suggested in your submission that the entire line of dies should be classified as a set within subheading
8207.30.6032, Harmonized Tariff Schedule of the United States (HTSUS), which provides for stamping dies
not suitable for cutting metal. As precedent to your proposed classification, you cite New York Ruling
N295035, dated March 30, 2018. We note that each individual die in that ruling was capable of forming
metal at the time of importation. It should also be noted that the dies were not classified as a set. In order to
classify a set for tariff classification purposes, all the items must be present at the time of importation. I n
your importation scenario, each die will be imported separately. Therefore, in accordance with General Rule
of Interpretation 1 of the HTSUS, classification will be determined by the function and condition of each
individual die at the time of importation.
The applicable subheading for the Trimming Die (OP20) will be will be 8207.30.3020, HTSUS, which
provides for interchangeable tools for handtools, whether or not power operated, or for machine-tools (for
example, for pressing, stamping, punching, tapping, threading, drilling, boring, broaching, milling, turning or
screwdriving), including dies for drawing or extruding metal, and rock drilling or earth boring tools; base
metal parts thereof : tools for pressing, stamping or punching, and parts thereof: suitable for cutting metal,
and parts thereof…tools. The general rate of duty will be 5.7 percent ad valorem.
The applicable subheading for the Drawing Die (OP10), Flanging Die (OP30), Restriking Die (OP40) and the
Hemming Die (HEM) will be 8207.30.6032, HTSUS, which provides for interchangeable tools for handtools,
whether or not power operated, or for machine-tools (for example, for pressing, stamping, punching, tapping,
threading, drilling, boring, broaching, milling, turning or screwdriving), including dies for drawing or
extruding metal, and rock drilling or earth boring tools; base metal parts thereof: tools for pressing, stamping
or punching, and parts thereof: not suitable for cutting metal, and parts thereof…stamping dies not suitable
for cutting metal. The general rate of duty will be 2.9 percent ad valorem.
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 South Korea will
be subject to an additional ad valorem rate of duty of 15 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.56, in addition to subheadings
8207.30.3020 and 8207.30.6032 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 Anthony Grossi at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division