CLA-2-73:OT:RR:NC:N5:116
David Hartnett
Nissin International Transport USA
900 Thorndale Avenue
Elk Grove Village, Illinois 60007
RE: The tariff classification of alloy steel tubing from Japan
Dear Mr. Hartnett:
In your letter dated January 8, 2026, you requested a tariff classification ruling on behalf of your client,
Konsei USA Inc.
The product under consideration is identified as a “bottle” housing for an automotive airbag inflator. This
seamless, cold-rolled, polished steel tube has an inside diameter of 30 mm, an outside diameter of 35.04 mm,
a wall thickness of 2.52 mm and measures261.2 mm (10.28 inches) in length. Based on the chromium
content, the tube meets the definition of an other alloy steel in accordance with Chapter 72, Note 1(f),
Harmonized Tariff Schedule of the United States (HTSUS).
You suggest classifying the “bottle” housing in subheading 8708.95.2000, HTSUS, which provides for motor
vehicles safety airbags with inflater system and parts thereof. We disagree. In the condition as imported, the
“bottle” housing is not an identifiable component of the inflater system, nor is it equipped with any
identifying features, such as fittings, seals, etc. It is imported as an empty tube; therefore, classification of the
“bottle” housing in subheading 8708.95.2000, HTSUS, is precluded.
The applicable subheading for the “bottle” housing will be 7304.51.5060, HTSUS, which provides for tubes,
pipes and hollow profiles, seamless, of iron (other than cast iron) or steel, other, of circular cross section, of
other alloy steel, cold-drawn or cold-rolled (cold-reduced), other, other, other. The rate of duty will be free.
Please be advised that alloy steel tubing from Japan may be subject to antidumping duties and/or
countervailing duties (AD/CVD). Written decisions regarding the scope of AD/CVD orders are issued by the
Enforcement and Compliance office in the International Trade Administration of the Department of
Commerce (ITA) and are separate from tariff classification and origin rulings issued by Customs and Border
Protection (CBP). General information regarding the ITA and AD/CVD can be found at
https://www.trade.gov/us-antidumping-and-countervailing-duties. The ITA’s “Guide on How to File for an
Antidumping/Countervailing Duty Scope Ruling Request” is available at
https://enforcement.trade.gov/scope/Request-Scope-Ruling.pdf.
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/current.
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 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, contact
National Import Specialist Angelia Amerson at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division