CLA-2-39:OT:RR:NC:N4:415
Timothy Rombach
Daimler Truck North America
4555 North Channel Avenue
Portland, OR 97217
RE: The tariff classification of a plastic steering column cover from Mexico.
Dear Mr. Rombach:
In your letter dated November 25, 2025, you requested a tariff classification ruling.
Images were provided in lieu of a sample.
The product under consideration is described as a “Cover-Steering Column,” part numbers 22-73811-002 and
227-3811-003, which is used in heavy-duty trucks. It is designed and shaped to cover the steering column
and provides an aesthetic finish to the bottom of the dashboard. The cover prevents the driver’s foot from
kicking and damaging the steering column. It fastens to the dashboard with two screws and hooks onto the
steering column at the bottom of the part.
You suggest classifying the cover within either subheading 8708.29, which provides for parts and accessories
of vehicle bodies, or subheading 8708.94, which provides for parts of steering columns. To support your
analysis, you cite New York rulings I84261, dated August 16, 2002, and H89467, dated March 28, 2002. We
disagree with these proposed classifications.
The rulings you cite describe articles that are different from the cover at issue. Furthermore, this item
appears to be a fitting within the terms of “parts of general use.” After the issuance of Jing Mei Automotive
(USA) v. United States, 682 F. Supp. 3d 1354 (Ct. Int’l Trade 2023), automotive fittings of plastics are to be
classified as “parts of general use” within subheading 3926.30.
The applicable subheading for the “Cover-Steering Column,” part numbers 22-73811-002 and 227-3811-003,
will be 3926.30.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for
“[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [f]ittings for furniture,
coachwork or the like: [o]ther.” The column one, general rate of duty is 5.3 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 CBP Regulations (19 CFR 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, contact
National Import Specialist Kristopher Burton at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division