CLA-2-87:OT:RR:NC:N2:206
TARIFF NO: 8708.70.4546
Wenjie Hu
Sailun (Vietnam) Co., Ltd.
Lot 37-1 41-20A, Street D11, Phuoc Dong Industrial Park, Gia Loc Ward,
Tay Ninh Province 843160
Vietnam
RE: The classification and country of origin of tire and rim assemblies
Dear Wenjie Hu:
In your letter dated December 11, 2025, you requested a classification and country of origin ruling on rubber
tires mounted on aluminum rims.
The three articles under consideration are 23*10R14 rubber tire mounted on 14*17 ET-20 aluminum rim,
225/50R14 rubber tire mounted on 14*7 ET-4 aluminum rim, and 23*10R14 rubber tire mounted on 14*7
ET-4 aluminum rim, which are used on golf carts. You state that each tire and rim assembly is at least 57 cm
in diameter but not more than 63 cm.
According to the information provided, the aluminum rims, center dust caps, and valve stems are produced in
China and sent to Vietnam for further assembly of with the Vietnam sourced rubber tires. The wheel
assembly process in Vietnam begins with installing the valve onto the rim and securing it on the turntable.
The tire is then mounted onto the rim according to directional markings and specialized equipment is used to
press the upper and lower beads of the tire into the rim groove. Once mounted, the tire is inflated to the
standard pressure inside a safety cage, and the valve cap and hub cover are installed.
The applicable subheading for the tire and rim assemblies will be 8708.70.4546, Harmonized Tariff Schedule
of the United States (HTSUS), which provides for “Parts and accessories to the motor vehicles of headings
8701 to 8705: Road wheels and parts and accessories thereof: For other vehicles: Other: Of aluminum:
Wheels having a diameter of at least 57 cm but not more than 63 cm.” 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.
When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,
Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a
substantial transformation will occur is whether an article emerges from a process with a new name,
character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v.
United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See
National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).
You assert that the country of origin of the tire and rim assemblies is Vietnam and cite ruling NY N317959,
dated March 8, 2021, which reviewed a similar scenario as in the present case to substantiate your analysis.
We disagree. In ruling N317959, the assembly process involved a bearing insertion from Japan. Furthermore,
because the character of the assembly could not be established, the cost comparison was made to determine
the origin. We stated, “…we do note that the assembly operation, irrespective of complexity, occurs in
Taiwan and constitutes the bulk of the work process as well as the majority of the manufacturing costs.”
In the current case, however, the bulk of the components is sourced in China and the cost of the Chinese
components is higher than of the Vietnamese. As a result, it is the opinion of this office, that the country of
origin of the tire and rim assembly will be China.
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