CLA-2-94:OT:RR:NC:N5:433
Katie In
World Asia Logistics Inc.
3483 Satellite Blvd., Suite 210S
Duluth, GA 30096
RE: The tariff classification of an automobile seat component from South Korea
Dear Ms. In:
In your letter dated November 07, 2025, on behalf of DAS North America, you requested a tariff
classification ruling. In lieu of samples, technical and illustrative literature, product descriptions, and
manufacturing processes were provided.
Item 1, Part No. 28310-ON740, the “Recliner ASSY – 7P40 Inner, LH,” is a seat component constructed of
low-alloy steel metal that will be installed on the seat frame of a motor vehicle. The seat component enables
both seatback angle adjustment and folding functions. The seatback reclining function allows the seatback
angle to be adjusted according to the occupant’s preferred position, providing both comfort and safety during
vehicle operation. The second row folding function enables the rear seatback to be folded forward to
increase cargo capacity, enhancing the vehicle’s versatility for various usage scenarios.
Item 2, Part No. 28400-MQA50, the “Track Sub Ass’y – 7P40 OTR, LH,” is a seat component constructed of
low-alloy steel metal that will be installed under the seat cushion frame of an automobile. The seat
component enables seat sliding for fore and aft adjustment for the driver and passenger convenience. Load
support allows the seat component to transfer occupant load safely to the vehicle floor. The seat component
is linked with airbag sensors and seat belt pretensioners, and ECU operation conditions. The seat component
provides ergonomic comfort tailored to the driver’s and passenger’s body position.
Item 3, Part No. 28130-MQ7E0, the “Cushion Mounting Bracket Assembly – Center, LH,” is a seat
component constructed of steel that will be installed as a structural linkage between the seat cushion frame
and the vehicle floor. The seat component supports the seat load, absorbing vibration and impact during
driving, and provides overall ride comfort and seat stability. The seat component provides sufficient
mounting rigidity at the bolt joint to minimize twisting or deformation of the back frame.
Item 4, Part No. 88547-TM701, the “Retainer ASSY,” is a seat component constructed of high carbon
chromium steel that will be installed between the upper and lower set rails within the seat track mechanism.
The seat component serves as a sliding and supporting component that ensures smooth seat movement and
prevents metal-to-metal friction. The retainer is positioned between the upper and lower rails, maintain the
correct clearance and minimizing friction.
The ruling request seeks classification of the subject merchandise in subheading 9401.99.1085, Harmonized
Tariff Schedule of the United States, (HTSUS). We agree.
The applicable subheading for the subject merchandise will be 9401.99.1085 HTSUS, which provides for
“Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Parts:
Other: Of seats of a kind used for motor vehicles: Other.” The general rate of duty will be free.
Trade Remedy:
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 from all countries,
including South Korea, will be subject to an additional 15 percent ad valorem rate of duty. At the time of
entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.56, in
addition to subheading 9401.99.1085, 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 Dharmendra Lilia at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division