CLA-2-87: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 adjustable levers for motorcycles
Dear Mr. Street:
In your letter dated October 27, 2025, you requested a tariff classification and country of origin determination
ruling.
The items under consideration have been identified as adjustable levers for motorcycles, specifically models
LEV-B000 and LEV-B100. You state that both models are the same, just for different models of
motorcycles. Adjustable levers allow riders to customize the distance and reach of their brake and clutch
levers for a more comfortable and controlled ride. You state that these items are supplied as replacement
parts for original manufacturers, as well as for performance enhancement.
You state in your request, and further demonstrated in the provided illustrations, that the finished unit
attaches in place of the original lever, converting the original setup to an adjustable version, with the option
of 3 styles of lever blade, and different colors of Blade or Switch. The items consist of 17 individual
components, all of which were designed and manufactured in your United Kingdom (UK) fa ctory, using UK
supplied raw materials and parts. Manufacturing and assembling of the products are done in house. Invoices
and a Bill of Materials (BOM) were submitted. You provided images and product literature, including fitment
instructions for the LEV-B100 - adjustable levers. From the information provided, the main parts of the
lever, which includes the brake cam, adjuster knobs, and actual brake levers are machine manufactured in
your UK facility. After completion they are hand assembled and packaged for retail sale. Each lever
assembly contains the following parts:
1. Brake Cam (1)
2. 24mm Adjuster Knob (1)
3. Adjuster Switch PTFE Bearing (1)
4.
3.
4. M3x 8 Socket Cap Head A4 (1)
5. 7MM Pivot Pin (1)
6. RWM0070 - 7mm Lever Clip (1)
7. Bearing - 10 x 5 x 4 (1)
8. M5 x 8 Grub Screw (1)
9. SPNG-COM-0007 3mm Ball Spring (1)
10. 3mm Ball Bearing (1)
11. Lever Spring (1)
12. Brake Lever Blade Custom (1)
In your request, you suggest classification for the adjustable levers, part numbers LEV-B000 and LEV-B100,
in subheading 8714.10.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for
parts of motorcycles. This office concurs.
The applicable subheading for LEV-B000 and LEV-B100 will be 8714.10.0050, HTSUS, which provides for
“Parts and accessories of vehicles of headings 8711 to 8713: Of motorcycles (including mopeds: 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 detailed illustrations, photos, and specific product certificates. YouTube
links were provided of the build/manufacturing process in your warehouse and the fitment
procedure/instructions of the levers on a motorcycle. In addition, you provided invoices showing that all raw
materials were sourced in the UK. It is the opinion of this office that the manufacturing processes, which
includes designing, CNC machining, lathing, and hand assembling, all of which that take place in the United
Kingdom are meaningful and substantial. As a result, the country of origin of the finished adjustable levers 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 8714.10.0050,
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 8714.10.0050, 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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division