CLA-2-84:OT:RR:NC:N2:201
Oliver Cadena
Ironcast de Frontera, S.A de C.V.
Libramiento Carlos Salinas de Gortari, Exterior Number 2001
Frontera
Mexico
RE: The tariff classification of cast-iron heavy-duty cylinder heads from Mexico
Dear Mr. Cadena:
In your letter dated November 11, 2025, you requested a tariff classification ruling.
The item under consideration has been identified as cast-iron cylinder heads, (Cylinder Head E7, part number
732GB5341M) designed for use in heavy-duty diesel vehicle engines. You state that within the production
process, no furnaces stress relief, annealing normalizing, quenching, and/or tempering is performed on the
cylinder heads cast in the facility. The castings are simply poured and allowed to cool naturally in the mold:
no heat treatment operations take place in the furnaces.
You provided a video showing the manufacturing process, which includes steps such as:
Mixing of sand
Iso-Cure/Cold Box
Core painting
Mold making
De-slagging
Pouring
Mold separation
Shot blasting
Grinding
Visual and Baroscopic inspection
Leak checking
Final packaging
You state that these cast-iron cylinder heads were manufactured from cast iron and do not contain steel.
The applicable subheading for the cast-iron cylinder heads, (Cylinder Head E7, part number
732GB5341M) will be 8409.99.1040, Harmonized Tariff Schedule of the United States (HTSUS), which
provides for “Parts suitable for use solely or principally with the engines of heading 8407 or 8408: Other:
Other: Cast-iron parts, not advanced beyond cleaning, and machined only for the removal of fins, gates,
sprues and risers or to permit location in finishing machinery: For vehicles of subheading 8701.21, 8701.22,
8701.23, 8701.24 or 8701.29, or heading 8702, 8703 or 8704.” The general rate of duty will be Free.
Products of Mexico as provided by heading 9903.01.01 in Section XXII, Chapter 99, Subchapter III, U.S.
Note 2(a), HTSUS, other than products classifiable under headings 9903.01.02, 9903.01.03, 9903.01.04, and
9903.01.05, HTSUS, will be subject to an additional 25 percent ad valorem rate of duty. At the time of entry,
you must report the applicable Chapter 99 heading, i.e. 9903.01.01, in addition to subheading 8409.99.1040,
HTSUS, listed above. Articles that are entered free of duty under the terms of general note 11 to the HTSUS
(U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set forth in subchapter XXIII of
Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be subject to the additional ad valorem
duties provided for in heading 9903.01.01. If your product is entered duty free as originating under the
USMCA, you must report heading 9903.01.04, HTSUS, in addition to subheading 8409.99.1040, HTSUS.
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 Mexico are not
subject to reciprocal tariffs. At the time of entry, you must report the Chapter 99 heading applicable to your
product classification, i.e. 9903.01.27, in addition to subheading 8409.99.1040, 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