CLA-2-40:OT:RR:NC:N5: 137

Madison Ratto
Light Speed Aviation
6135 Jean Road
Lake Oswego, OR 97035

RE: The tariff classification of a nitrile O-ring from the Philippines

Dear Ms. Ratto:

In your letter dated November 22, 2025, you requested a tariff classification ruling.

SKU number 305-0006-100.A3, O-ring boom is a nitrile rubber O-ring. The dimensions are 12.14 mm inner diameter, 17.60 mm outer diameter, and 2.612 mm in width. The O-ring is used in the production of noise cancelling aviation headsets. It creates a seal that prevents air leaks that interfere with noise cancelling performance and acts as a secondary barrier against sweat, moisture, and dust. It is noted that the O-ring can be used in other assemblies.

The applicable subheading for the nitrile rubber O-ring will be 4016.93.5010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of vulcanized rubber other than hard rubber: other: gaskets, washers and other seals: other: O-rings. The general rate of duty will be 2.5 percent ad valorem.

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 the Philippines will be subject to an additional ad valorem rate of duty of 19 percent. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.53, in addition to subheading 4016.93.5010, 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 Christina Allen at [email protected].
Sincerely,

(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division