CLA-2-87:OT:RR:NC:N2:206
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 three steel automobile structural components, Part Numbers 89639.20.001.04,
89722.20.001.06, and 89718.20.001.08, 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.
89639.20.001.04 is a rectangular component of 36 mm x 24.5 mm x 1078.1 mm (length), with a wall
thickness of 2.4 mm. It is produced from cold-rolled steel coils and is neither painted nor coated. This
component is specifically machined to be a component of the cross beam structural assembly of a Ford F250.
It features one hole that is specifically placed in accordance with customer specifications to receive other
components of the structural assembly.
89722.20.001.06 features an outside diameter of 69 mm, a wall thickness of 2 mm, and a length of 485.8 mm.
It is produced from hot-rolled steel coils and is neither painted nor coated. This component is specifically
machined to be a component of the cross beam structural assembly of a Ford Mustang. I t features two holes
and a large slot that are specifically placed in accordance with customer specifications to receive other
components of the structural assembly.
89718.20.001.08 features an outside diameter of 32 mm, a wall thickness of 2 mm, and a length of 955.5 mm.
It is produced from hot-rolled steel coils and is neither painted nor coated. This component is specifically
machined to be a component of the cross beam structural assembly of a Ford Mustang. I t features three holes
of varying diameters that are specifically placed in accordance with customer specifications to receive other
components of the structural assembly.
You suggest that all three components be classified in subheading 8708.29.5160, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for parts of vehicle bodies. We partially disagree. In
its condition as imported, Part Number 89639.20.001.04 is not advanced beyond a pipe and is not identifiable
as a motor vehicle component. As a result, classification of Part Number 89639.20.001.04 in subheading
8708.29.5160, HTSUS, is precluded.
The applicable subheading for Part Number 89639.20.001.04, having an aluminum content less than 0.3
percent, a niobium content less than 0.06 percent, and/or a titanium content less than 0.05 percent will be
7306.61.5000, HTSUS, which provides for other tubes, pipes and hollow profiles (for example, open seamed
or welded, riveted or similarly closed), of iron or steel: Other, welded, of noncircular cross section: of square
or rectangular cross section: having a wall thickness of less than 4 mm: of iron or nonalloy steel. The rate of
duty will be Free.
The applicable subheading for Part Number 89639.20.001.04, having an aluminum content of 0.3 percent or
more, a niobium content of 0.06 percent or more, and a titanium content of 0.05 percent or more will be
7306.61.7060, HTSUS, which provides for other tubes, pipes and hollow profiles (for example, open seamed
or welded, riveted or similarly closed), of iron or steel: Other, welded, of noncircular cross section: of square
or rectangular cross section: having a wall thickness of less than 4 mm: of alloy steel: other. The rate of duty
will be Free.
The applicable subheading for Part Numbers 89722.20.001.06 and 89718.20.001.08 will be 8708.29.5160,
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 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