CLA-2-84:OT:RR:NC:N1:102
Queenie Zhong
Broad Falcon Co., Ltd.
189 Moo 4, Map Phai, Ban Bueng District
Chon Buri 20170
Thailand
RE: The tariff classification and country of origin of a timing chain kit
Dear Ms. Zhong:
In your letter dated October 22, 2025, you requested a tariff classification and country of origin determination
ruling. Descriptive information was provided with the submission.
The item under consideration is a Timing Chain Kit, item 9-4200SA. The items in the kit consist of a timing
chain guide, a timing chain, a tensioner assembly, and two sprockets (a camshaft and a crankshaft sprocket)
packaged together ready for retail sale. The items, which are primarily constructed of steel, are used to
replace the timing system of an internal combustion engine used in motorized vehicles (sedans, sport utility
vehicles, crossover utility vehicles, minivans and cargo vans).
The repair kit, which constitutes goods classified in two or more headings, is put up in a set ready for retail
sale. Goods that are, prima facie, classifiable under two or more headings, are classifiable in accordance with
General Rule of Interpretation (GRI) 3, Harmonized Tariff Schedule of the United States (HTSUS). GRI 3(a)
states in part, when two or more headings each refer to part only of the materials or substances contained in
mixed or composite goods, those headings are to be regarded as equally specific, even if one heading gives a
more precise description of the good. Goods classifiable under GRI 3(b) are classified as if they consisted of
the material or component which gives them their essential character, which may be determined by the nature
of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in
relation to the use of the article.
Here, the purpose of a timing system is to transmit rotary power, and more importantly to maintain an exact
speed ratio between the rotation of the crankshaft and the camshaft. It is the sprocket s, which are forged of
steel material, that impart the essential character, as they establish the desired speed ratio to maintain the
timing of the engine. In accordance with GRI 3(b), we find the entire set is classified within heading 8483,
which provides for gears and gearing.
If the sprockets are forged, the applicable subheading for the timing chain kit will be 8483.90.1010, 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: Toothed wheels, chain sprockets and other transmission
elements presented separately; parts: Chain sprockets and parts thereof: Forged. The general rate of duty is
2.8 percent ad valorem.
If the sprockets are not forged, the applicable subheading for the timing chain kit will be 8483.90.1050,
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: Toothed wheels, chain sprockets and other
transmission elements presented separately; parts: Chain sprockets and parts thereof: Other. The general rate
of duty is 2.8 percent ad valorem.
With respect to origin, you explain that the items, which are packaged together in Thailand, are of Thai
origin. The timing chain is assembled in Thailand using plates, pins, bushings and rollers from Thailand. The
timing chain guide is formed using an injection molding process, which is afterwards machined in Thailand.
The tensioner assembly is assembled in Thailand using components sourced from China (a housing, a spring,
and a plunger). The sprockets are also formed in Thailand after machining, heat treating and coating raw
material from China. It is subsequent to the processes that occur in Thailand that the sprockets feature an
outer profile with teeth and a center hub with a specific shape and dimensions.
Country of Origin Guidance in a situation where sets packaged for retail sale are involved is provided on the
CBP website in “CBP Section 301 Trade Remedies Frequently Asked Questions.” The answer to “How are
the Section 301 duties assessed in respect to sets packaged for retail sale, which contain components covered
by the Section 301 remedy,” reads, in pertinent parts, as follows: When importing goods put up in sets for
retail sale (in accordance with General Rule of Interpretation 3) that contain articles subject to the Section
301 remedy, if the product that imparts the essential character to the set (i.e., the HTSUS provision under
which the entire set is classified) is covered by the Section 301 remedy, then the entire set will be subject to
the additional duties. If the HTSUS provision under which the entire set is classified is not covered by the
Section 301 remedies, but the set contains components that are classified in a subheading covered by the 301
list, the 301 duties will not be assessed on the individual components. Following this guidance, the sprockets,
which are products are of Thailand, impart the essential character of the kit. Accordingly, the country of
origin of the repair kit for Section 301 Trade Remedies and additional duties is Thailand.
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 Thailand will be
subject to an additional ad valorem rate of duty of 19 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e., 9903.02.61, in addition to subheading
8483.90.1010 or 8483.90.1050, 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 Sandra Martinez at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division