CLA-2-84:OT:RR:NC:||CEE010||:N1:104
Karen Hernandez Rosales
Pie Consulting
Av. Lazaro Cardenas 2224, Zona Loma Larga Oriente
San Pedro Garza Garcia 66266
Mexico
RE: The tariff classification of an electronically controlled vehicle brake system from Mexico
Dear Ms. Hernandez:
In your letter dated November 11, 2025, on behalf of your client, Hyundai Mobis S. de R.L. de C.V., you
requested a tariff classification ruling.
The item in question is the iMEB assembly, part no. XL585-00000, which is an electronically controlled
vehicle brake system that integrates the functions of a conventional vacuum booster with an active electronic
control mechanism. The iMEB is comprised of several components: an Electronic Control Unit (ECU)
(which determines the vehicle’s braking condition and activates the iMEB’s motor and solenoid valves), a
pedal stroke sensor, pressure sensor, piston pump assembly, a pedal piston pump assembly, a reservoir
assembly, a housing with internal hydraulic passages, and a bracket for securing internal vehicle wiring.
When the driver operates the brake pedal, the ECU detects pedal movement and regulates a double-acting
piston pump assembly to supply hydraulic brake fluid to the wheel calipers, thereby generating the braking
pressure required for braking. The iMEB’s pedal piston pump provides the driver with a braking feeling
equivalent to that of a conventional brake system. Finally, the iMEB has an active electronic control function
that receives signals from the iMEB’s sensors and synthesizes them to make adjustments to performance,
stability, and safety including controlling braking force, drive force, and yaw moment of each wheel. The
iMEB is installed in the dash panel inside the vehicle’s engine compartment.
In your letter, you suggest the iMEB assembly should be classified within heading 8413, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for pumps for liquids. We disagree, as the
assembly’s functionality extends beyond that of pumping fluid, incorporating components crucial to other
aspects of the braking process, such as electronic stability control. This broader functionality aligns with
CBP’s previous classification of similar integrated braking assemblies, such as in New York Ruling
N332229, dated April 28, 2023, in which an integrated braking assembly was classified as a mechanical
appliance with individual functions not specified or included elsewhere in Chapter 84. Accordingly, the
iMEB assembly is excluded from heading 8413.
The applicable subheading for the iMEB assembly will be 8479.89.9599, HTSUS, which provides for
Machines and mechanical appliances having individual functions, not specified or included elsewhere in this
chapter; parts thereof: Other machines and mechanical appliances: Other: Other: Other. The general rate of
duty will be 2.5% ad valorem.
On March 12, 2025, Presidential Proclamation 10895 imposed additional tariffs on certain derivative
aluminum products. Additional duties for derivative aluminum products of 50 percent are reflected in
Chapter 99, headings 9903.85.04, 9903.85.07, and 9903.85.08. Products provided by heading 9903.85.08, as
well as products of Chapter 76 provided by 9903.85.04 and 9903.85.07, will be subject to a duty of 50
percent upon the value of the aluminum content. At the time of entry, you must report the Chapter 99 heading
applicable to your product classification, i.e. 9903.85.08, in addition to subheading 8479.89.9599, HTSUS.
Derivative aluminum articles processed in another country from aluminum articles that were smelted and cast
in the United States, provided for in heading 9903.85.09, are not subject to the additional ad valorem duties.
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. For products
covered by heading 9903.85.08 this additional duty applies to the non-aluminum content of the merchandise.
At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.01, in addition to
subheading 8479.89.9599, 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 8479.89.9599, 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 8479.89.9599, 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 Arthur Purcell at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division