CLA-2-87:OT:RR:NC:N2:206
Megan Ealey
AFC International
3658 Atlanta Industrial Dr NW B
Atlanta, GA 30331
RE: The tariff classification of pet transport crates from the United Kingdom
Dear Ms. Ealey:
In your letter dated November 24, 2025, you requested a tariff classification ruling on behalf of your client,
TranksK9 USA, Inc.
The articles under consideration are pet transport crates, model numbers C35, C42, C49, C50, and C57,
which are specifically made for safe, vehicle transport of pets to be installed in the cargo area, behind the
second-row seat of sports utility vehicles (SUVs), wagons, vans, and the bed of pick-up trucks. They are
shaped to fit the unique spaces of each vehicle type and vehicle model. You state that they are not suitable for
airline transport, home containment or outdoor containment. They are not collapsible nor foldable and cannot
be disassembled other than a removable center divider for the double door model. The products are used
primarily by law enforcement/military K9s, animal control, professional dog trainers, and many private pet
owners to safely transport pets in vehicles.
Models C35, C49, and C50 are aluminum crates equipped with steel double doors and designed to conform to
the frame of a specific vehicle trunk, depending on the model of the car. Each model takes up almost the
entire space of the vehicle trunk.
Models C42 and C57 are also made of aluminum and equipped with a steel single door. They do not conform
to the frame of the vehicle trunk but rather placed on the bed of the trunk with ample space in the trunk.
All crate models are made with integrated strapping holes to run ratchet straps to secure at the discretion of
the customer.
In your letter, you suggested classification of the crates in subheading 8708.99.8180, Harmonized Tariff
Schedule of the United States (HSTUS), which provides for motor vehicle parts and accessories. We partially
disagree. Models C42 and C57 are not motor vehicle accessories, as they do not contribute to the
effectiveness of the vehicle. Unlike models C35, C49, and C50, which become essentially the vehicle trunk
space, models C42 and C57 are not designed for specific vehicles and are easily placed in and removed from
the vehicle.
The applicable subheading for the pet transport crates, model numbers C35, C49, and C50 will be
8708.99.8180, HTSUS, which provides for “Parts and accessories of the motor vehicles of heading 8701 to
8705: Other parts and accessories: Other: Other: Other: Other: Other: Other.” The general rate of duty will
be 2.5 percent, ad valorem.
The applicable subheading for the pet transport crates, model numbers C42 and C57 will be 7616.99.5190,
HTSUS, which provides for “Other articles of aluminum: Other: Other: Other: Other: Other: Other.” The
general rate of duty will be 2.5 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
(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 Liana Alvarez at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division