CLA-2-73:OT:RR:NC:N1:164
Madison Ratto
Light Speed Aviation
6135 Jean Road
Lake Oswego, OR 97035
RE: The tariff classification of a spring from the Philippines
Dear Madison Ratto:
In your letter dated November 16, 2025, you requested a tariff classification ruling regarding a spring from
the Philippines. Product information was submitted with your request.
The spring under consideration is referred to as “Spring, Arm” (Item 314-00003-000.B4). It is described as a
component that will be installed into the “Sierra” model of noise canceling aviation headset. Specifically, the
high carbon steel spring will be assembled into the inside of the headset’s headband assembly. You state that
the spring allows the headband to flex repeatedly without losing shape or clamping force over time. In
addition, it allows for adjustability, absorbs and dampens vibrations, and acts as a binder which supports
other components within the headband assembly such as padding and wiring.
Based on the submitted documents, the spring at issue is a helical spring. At both ends, the wire extends
laterally from the main coil and curves inward at approximately 90 degrees to form two “arms.” The
submitted pictures show that the arms allow the spring to connect to and provide tension to surrounding
components. As noted on the submitted drawing, the wire measures 1.91 millimeters (mm) in cross sectional
diameter. Additionally, the coil has an outside diameter of approximately 10 mm and measures 22.6 mm in
length.
Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is
governed by the General Rules of Interpretation (GRIs). GRI 1 provides that classification is determined first
in accordance with the terms of the headings of the tariff and any relative section or chapter notes. Note 1(g)
to Section XVI and Note 2(b) to Section XVII exclude “Parts of general use as defined in note 2 to section
XV, of base metal (section XV) or similar goods of plastics (chapter 39).” Note 2(b) to Section XV lists
springs and leaves for springs, of base metal, as parts of general use.
The applicable subheading for the Spring, Arm (Item 314-00003-000.B4) will be 7320.20.5020, HTSUS,
which provides for Springs and leaves for springs, of iron or steel: Helical Springs: Other: Helical springs, of
wire having a cross-sectional dimension of less than 5.1 mm: Other. The general rate of duty will be 3.9
percent ad valorem.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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
(C.F.R.), 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 C.F.R. 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 Paul Taylor at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division