CLA-2-84:OT:RR:NC:N1:103
Joseph Stevens
ALU Industries LLC
150 Hamakua Dr., PMB424
Kailua, HI 96734
RE: The tariff classification of a pallet jack and wheel from China
Dear Mr. Stevens:
In your letter dated December 12, 2025, you requested a tariff classification ruling.
The first item under consideration, model number HPT25, is a manual pallet jack used to lift and move
palletized loads. It has a handle, a hydraulic pump system, and forks, which are metal arms that slide
underneath a pallet or skid. The handle functions both as a pump handle and as a steering mechanism. The
operator pumps the handle to raise the load and then pushes the pallet jack to its destination. This model has a
2,500-kilogram lifting capacity, a 27-inch overall width, and forks that are 48 inches in length.
The second item under consideration is identified as a solid rubber wheel used in hand trucks and delivery
carts. It consists of a rubber tread that is glued to an aluminum core. The wheel has an 8-inch diameter and a
1.59-inch tire width.
The applicable subheading for the manual pallet jack, model number HPT25, will be 8427.90.0090,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Fork-lift trucks; other works
trucks fitted with lifting or handling equipment: Other trucks: Other.” The general rate of duty will be free.
The applicable subheading for the solid rubber wheel will be 4012.90.1000, HTSUS, which provides for
“Retreaded or used pneumatic tires of rubber; solid or cushion tires, tire treads and tire flaps, of rubber:
Other: Solid or cushion tires.” The general rate of duty will be free.
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 Paul Huang at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division