CLA-2-84:OT:RR:NC:N1:102
Julie Monger
Tricord Business Group
2751 Legends, Pkwy #151
Prattville, AL 36066
RE: The tariff classification of a guide rail assembly from India
Dear Ms. Monger:
In your letter dated October 24, 2025, you requested a tariff classification ruling on behalf of your client,
Braunability. Descriptive information was provided with your submission
The product in question is a linear guide rail assembly. The rail assembly is comprised of item HSR20C1SS,
which consists of two blocks, and a rail, item HSR20CA. Each block functions as a carriage that contains 128
ball bearings. The bearings recirculate as the carriage runs on a loading rail that is aligned to the carriage of
the ramp. Once the ramp is mounted onto the substructure of a Honda, a Toyota, or a Chevrolet in-floor
vehicle, the assembly allows for smooth, load-bearing ramp deployment and retraction. The assembly is
constructed of steel that is coated with an advanced polymer hard chrome.
The applicable subheading for the linear guide rail assembly will be 8482.10.5012, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for Ball or roller bearings, and parts thereof: Ball
bearings: Other: Other: Linear bearings. The general rate of duty will be 9 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 8482.10.5012, 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 August 27, 2025, Executive Order 14329 imposed additional duties on products from India. At this
time, products of India provided by heading 9903.01.84, except for products described in headings
9903.01.85 – 9903.01.89, will be subject to an additional ad valorem rate of duty of 25 percent. 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.,
9903.01.84, in addition to subheading 8482.10.5012, HTSUS, listed above.
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 India will be
subject to an additional ad valorem rate of duty of 25 percent. 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., 9903.02.26, in addition to subheading
8482.10.5012, HTSUS, listed above.
In your submission, you request consideration of a secondary classification for the assembly above under
9817.00.96, HTSUS, which applies to articles and parts of articles specifically designed or adapted for the
use or benefit of the permanently or chronically physically or mentally handicapped. Chapter 98, Subchapter
XVII, U.S. Note 4(a), HTSUS, defines the term blind or other physically or mentally handicapped persons as
including “any person suffering from a permanent or chronic physical or mental impairment which
substantially limits one or more major life activities, such as caring for oneself, performing manual tasks,
walking, seeing, hearing, speaking, breathing, learning, or working.”
The primary issue is whether the article is specially designed or adapted for the use or benefit of the
handicapped within the meaning of Nairobi Protocol. Although the legislative history of the Nairobi Protocol
discusses the concerns of Congress that the design, modification, or adaptation of an article must be
significant so as to clearly render the article for use by handicapped individuals, no specific definition of
these terms was established by Congress. Since it is difficult to establish a clear definition of what is
specially designed or adapted, various factors must be utilized on a case-by-case basis to determine whether a
given article is specially designed or adapted within the meaning of this statute.
In Treasury Directive 92-77, dated August 3, 1992 (Volume 26 Customs Bulletin Issue 35, dated August 26,
1992), U.S. Customs and Border Protection (CBP) set forth its position regarding certain issues arising under
the Nairobi Protocol. The first issue concerned the interpretation of the term specially designed or adapted.
CBP pointed out that a primary factor to be considered in determining whether an article was specially
designed and adapted was whether the article was easily distinguishable, by properties of the design and the
corresponding use specific to this unique design, from articles useful to non-handicapped individuals.
Therefore, if an article is solely dedicated for use by the handicapped it is CBP’s position that this would be
conclusive evidence that the article is specially designed or adapted for the handicapped for purposes of the
Nairobi Protocol.
In Headquarters Ruling Letter 556449, dated May 5, 1992, CBP set forth five factors it would consider in
determining whether an article is specially designed or adapted for the use or benefit of handicapped persons.
These factors include: (1) the physical properties of the article itself (i.e., whether the article is easily
distinguishable by properties of the design, form, and the corresponding use specific to this unique design,
from articles useful to non-handicapped persons); (2) whether any characteristics are present that create a
substantial probability of use by the chronically handicapped so that the article is easily distinguishable from
articles useful to the general public and any use thereof by the general public is so improbable that it would
be fugitive; (3) whether articles are imported by manufacturers or distributors recognized or proven to be
involved in this class or kind of articles for the handicapped; (4) whether the articles are sold in specialty
stores which serve handicapped individuals; and (5) whether the condition of the articles at the time of
importation indicates that these articles are for the handicapped.
Based on the information provided, the linear guide assembly does not satisfy the five factors set out by CBP.
The assembly is an intermediate product that reduces friction and facilitates the motion of the ramp as it is
deployed and retrieved for storage. The assembly itself is not directly contributing to the process of
transitioning onto a vehicle. Furthermore, the assembly does not have physical properties or special features
that make it readily distinguishable from linear guide assemblies used in common good ramps. The assembly
does not have features that prevent their use in machines or ramps that are used in other applications. Based
on these considerations, there is no indication that the linear guide assembly is specially designed or adapted
for the use or benefit of the handicapped. As such, the linear guide assembly does not satisfy the description
set forth in Chapter 98, Subchapter XVII, U.S. Note 4(a) and are not eligible for HTSUS provision
9817.00.96.
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