CLA-2-84:OT:RR:NC:N2:201

Stephen Street
Oberon Performance Ltd
11&12 Havant Business Centre, Harts Farm Way
Havant PO9 1HU
United Kingdom

RE: The tariff classification and country of origin of clutch slave cylinders

Dear Mr. Street:

In your letter dated October 22, 2025, you requested a tariff classification and country of origin determination ruling.

The item under consideration has been identified as a motorcycle clutch slave cylinder, specifically models CLU-0116, CLU-0120, CLU-0121, CLU-1125, and CLU-4000. You state that all models are the same product, just for different models of motorcycle. The finished unit bolts to the side of the motorcycle engine (on those that rely on a hydraulic actuator to operate the separation of the clutch plates) and transmits hydraulic pressure from the master cylinder, at the clutch lever, to the clutch pushrod. You state that these parts are supplied as replacement parts to original manufacturers, as well as for performance enhancement.

You state in your request, and further demonstrated in the provided illustrations and video, that the clutch slave cylinders are comprised of ten (10) individual components, all of which were designed and manufactured in your United Kingdom (UK) factory, using UK supplied raw materials, such as billets and rods. You also indicate that, in addition to manufacturing, you also assemble the product in-house, then distribute it to specialist resellers in the USA.

In your request, you suggest classification of the clutch slave cylinders in heading 8714, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and accessories of … motorcycles.” We disagree. While these components are designed and used on motorcycles they are more specifically provided for elsewhere in the nomenclature. The applicable subheading for the motorcycle clutch slave cylinder, models CLU-0116, CLU-0120, CLU-0121, CLU-1125, and CLU-4000, will be 8412.21.0075, HTSUS, which provides for “Other engines and motors, and parts thereof: Hydraulic power engines and motors: Linear acting (cylinders): Other: Other.” The general rate of duty will be Free.

When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).

In your submission you provided a comprehensive video showing the manufacturing process, which includes lathing, CNC cutting, anodizing, and other manufacturing processes that turn raw billets and other materials into finished products. It is the opinion of this office that the manufacturing processes that take place in the United Kingdom are meaningful and substantial, and that as a result the country-of-origin of the finished clutch slave cylinders is the United Kingdom.

On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or steel products. Additional duties of 25% for derivative iron or steel products of the United Kingdom are reflected in Chapter 99, headings 9903.81.96, 9903.81.97, and 9903.81.98. Products provided by heading 9903.81.98, as well as products of Chapter 73 provided by 9903.81.96 and 9903.81.97, will be subject to a duty of 25% 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. 9903.81.98, in addition to subheading 8412.21.0075, 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 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 United Kingdom will be subject to an additional ad valorem rate of duty of 10 percent. For products covered by heading 9903.81.98, 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. 9903.02.66, in addition to subheading 8412.21.0075, 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