CLA-2-87:OT:RR:NC:N:206
Matthew Seymour
GDLSK LLP
599 Lexington Ave,
New York, NY 10022
RE: The tariff classification of steel automotive components from Canada.
Dear Mr. Seymour:
In your letter dated December 8, 2025, you requested a tariff classification ruling on behalf of Kirchhoff
Automotive USA, Inc.
The products at issue are four steel automobile components, Part Numbers 88682.20.001.04,
89110.20.001.05, 8683.20.001.06, and 89109.20.001.05, which will be assembled into cross-car beams,
which are also known as instrumental panel beams. Once assembled the completed structural assembly will
be used to complete the dashboard, which is also where the steering wheel assembly will be mounted. Each
article is of a tubular shape and produced from cold-rolled steel coils and is neither painted nor coated.
88682.20.001.04 has an outside diameter of 31.8mm, a wall thickness of 1mm, and a length of 934.9mm. It is
designed to be used with the cross beam assembly of a Honda Civic. It features four holes, a large slot, and
notch on one of its ends that are specifically placed in accordance with customer specifications to receive
other components of the structural assembly.
89110.20.001.05 has an outside diameter of 31.8mm, a wall thickness of 1mm, and a length of 987.7mm. It is
designed to be used with the cross beam assembly of a Honda CRV. It features seven holes, a slot, and a
notch on one of its ends that are specifically placed in accordance with customer specifications to receive
other components of the structural assembly.
88683.20.001.06 has with an outside diameter of 60.5mm, a wall thickness of 2.3mm, and a length of
518.3mm. It is designed to be used with the cross beam structural assembly of a Honda Civic. It features
seven strategically machined holes and a notch on one of its ends that are specifically placed in accordance
with customer specifications to receive other components of the structural assembly.
89109.20.001.05 has an outside diameter of 60.5mm, a wall thickness of 2.3mm, and a length of 544.9mm. It
is designed to be used with the cross beam assembly of a Honda CRV. It features seven strategically
machined holes and a notch on one of its ends that are specifically placed in accordance with customer
specifications to receive other components of the structural assembly.
The applicable subheading for the steel automobile components, Part Numbers 88682.20.001.04,
89110.20.001.05, 88683.20.001.06, and 89109.20.001.05, will be 8708.29.5160, Harmonized Tariff Schedule
of the United States (HTSUS), which provides for “Parts and accessories of the motor vehicles of heading
8701 to 8705: Other parts and accessories of bodies (including cabs): 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