CLA-2-83:OT:RR:NC:N5:121
Maximilian Glatz
STS Oberholz GMBH & Co KG
Oststrasse 15
Velbert 42551
Germany
RE: The tariff classification of metal latch/lock assemblies from Germany
Dear Mr. Glatz:
In your letter dated October 24, 2025, you requested a tariff classification ruling.
The products under consideration are two styles of base metal latch/lock assemblies: the SLIM-Line and the
CUBE-Line. Each style is a complete key-operated mechanical latch/lock made of base metals (zinc alloy,
steel and aluminum) and a small plastic cap. These locks will be installed on the storage compartment flap or
door in caravans, travel trailers, or motorhomes (RVs) to secure luggage, tools, or utility spaces. You state
that they are not designed or marketed for passenger automobiles or light trucks.
You suggested that these complete base metal latch/lock assemblies be classified under subheading
8301.60.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Padlocks and
locks (key, combination or electrically operated), of base metal: … Parts. We disagree. These are complete
locks, not parts of locks. You also suggested that these locks are not “of a kind used on motor vehicles”
within the meaning of subheading 8301.20, because caravans/travel trailers are trailers (heading 8716) and
not self-propelled motor vehicles. However, as stated these locks are also suitable for use in motorhomes
(RVs) (heading 8703) which are motor vehicles principally designed for the transport of persons for tariff
purposes.
The applicable subheading for the SLIM-Line and the CUBE-Line base metal latch/lock assemblies will be
8301.20.0060, HTSUS, which provides for Padlocks and locks (key, combination or electrically operated) of
base metal; clasps and frames with clasps, incorporating locks, of base metal; keys and parts of any of the
foregoing articles, of base metal: Locks of a kind used on motor vehicles: Other. The rate of duty will be 5.7
percent ad valorem.
Effective May 3, 2025, Presidential Proclamation 10908 imposed additional tariffs on certain automobile
parts. At this time, parts of passenger vehicles and light trucks that are products of the European Union, as
provided in subdivision (o) of U.S. note 33 to this subchapter, 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. 9903.94.53, in addition to subheading 8301.20.0060,
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 the Germany
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. Your
product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading
applicable to your product classification, i.e. 9903.01.33, in addition to subheading 8301.20.0060, HTSUS,
listed above.
In your letter, you suggest that the SLIM-Line and the CUBE-Line base metal latch/lock assemblies may be
subject to 9903.94.06, HTSUS, which states: Effective with respect to entries on or after May 3, 2025,
articles provided for in subdivision (h) of U.S. note 33 to this subchapter. Subdivision (h) states:
Heading 9903.94.06 applies to all entries of articles classifiable under provisions of the HTSUS enumerated
subdivision (g) of this note:
(i) that are eligible for special tariff treatment under the United States-Mexico-Canada Agreement
(USMCA), other than automobile knock-down kits or parts compilations; or
(ii) that are not parts of passenger vehicles (sedans, sport utility vehicles, crossover utility vehicles,
minivans, and cargo vans) and light trucks.
These latch/lock assemblies are made in Germany and not eligible for treatment under the USMCA,
therefore, (i) is not satisfied. The latch/lock assemblies are also clearly intended for use with passenger
vehicles such as motorhomes (RVs) therefore, (ii) is not satisfied. Consequently, heading 9903.94.06 will not
be applicable to the latch/lock assemblies subject to this ruling.
Please be advised that the issue you raised on the applicability of harbor maintenance fees (HMF) and
merchandise processing fees (MPF) per standard rules pertains to valuation, which falls outside the purview
of this office. If you are seeking a ruling on applicability of HMF/MPF, requests for valuation rulings should
be addressed to Chief, Valuation and Special Programs Branch, Regulations and Rulings, CBP Office of
Trade, 90 K Street, NE, 10th Floor, Washington, DC 20229.
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 Jennifer Jameson at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division