CLA-2-84:OT:RR:NC:N1:102
David Hartnett
Nissin International Transport USA
900 Thorndale Avenue
Elk Grove Village, IL 60007
RE: The tariff classification of gear units from Japan
Dear Mr. Hartnett:
In your letter dated October 30, 2025, you requested a tariff classification ruling on behalf of Resonac
Powdered Metals America Inc. Descriptive information was provided with the submission
The items under consideration are gear units, part numbers 13632-36030-US and 13634-36050-US. The gear
units feature an outer profile of teeth constructed of plastic material and aramid fibers, and a center hub that
is constructed of steel material. The gears are designed to transfer rotational power to a balance shaft located
within the engine of a motor vehicle. As the balance shaft rotates in the opposite direction of the engine’s
rotation, vibration and noise are reduced.
In your letter, you suggest the gear units are classified within subheading 8708.99.5500, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for Parts and accessories of the motor vehicles of
headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Vibration control goods containing
rubber. We disagree, as the gear units are not integral component parts of a vehicle. They are integral
component parts of an engine used in a vehicle. Section Note 2(e) to Section XVII excludes machines or
apparatus of headings 8401 to 8479, or parts thereof, other than the radiators for the articles of this section;
articles of heading 8481 or 8482 or, provided they constitute integral parts of engines or motors, articles of
heading 8483. Gears and gearing are specifically provided for within heading 8483. As such, the gear units
are excluded from subheading 8708.99.5500.
The applicable subheading for the gear units will be 8483.90.5080, 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: Parts of gearing, gear boxes and other speed changers: Other. The general rate of duty will be 2.5
percent ad valorem.
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter
99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as
products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 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., 9903.81.91, in addition to subheading 8483.90.5080, 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 Japan 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. For products
covered by heading 9903.81.91 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.,
9903.02.73, in addition to subheading 8483.90.5080, 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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division