CLA-2-84:OT:RR:NC:N1:103
Bill Krayer
Kito Crosby Ltd.
410 West End Boulevard
Manheim, PA 17545
RE: The tariff classification of a chain hoist body and a load chain from Japan
Dear Mr. Krayer:
In your letter dated January 28, 2026, you requested a tariff classification ruling.
The articles under consideration are components for the NER2W series of electric chain hoists, which are
described as high-speed hoists used in wind tower applications. A complete NER2W chain hoist will have a
hoist body, a load chain, a chain container, a power supply assembly, a radio assembly, a remote control,
brackets, and installation hardware.
The hoist body is the main assembly and is described as a metal structural housing that contains an electric
motor, a brake drum assembly, a clutch assembly, and a gearbox. The unit has a lifting capacity of 0.25 tons
and a lifting speed of 70 feet per minute at 60 hertz.
The load chain is described as a nonalloy steel load chain for use in an electric chain hoist. This welded link
chain is composed of oval interlocking links that are 4 mm in diameter. The chain is imported without fittings
and in varying lengths between 76 meters and 135 meters. After importation, the chain will be fitted with
hooks and assembled into a hoist body.
You state that the load chain is imported in barrels along with the separately packaged hoist body. The
importation does not include the following components to complete the chain hoist: (1) radio assembly, (2)
remote control, (3) chain container and hardware, (4) suspender, and (5) power supply assembly. After the
components are imported, they will be combined with the chain hoist body and then shipped to your
customer.
You suggest that the subject chain hoist and chain are classified in heading 8425, Harmonized Tariff
Schedule of the United States (HTSUS), as an unassembled article pursuant to General Rule of Interpretation
(GRI) 2(a). We disagree. Based on the nature of the product and the condition of the components at the time
of importation, the components do not qualify as unassembled hoists.
GRI 2(a) provides, in pertinent part, that “Any reference in a heading to an article shall be taken to include a
reference to that article complete or finished (or falling to be classified as complete or finished by virtue of
this rule), entered unassembled or disassembled.” Here, the components in the proposed transaction do not
constitute a complete electric chain hoist. Additional components such as a power supply assembly and a
radio assembly are assembled to the hoist body in the United States. As such, we find that the components in
the proposed transaction are not identifiable as an unassembled or disassembled article, but are components
imported in bulk as inventory for electric chain hoist assembly operations.
We also considered if the subject goods can be classified as an “unassembled set.” The classification of sets
is governed by GRI 3(b). Harmonized System Explanatory Note (X) to GRI 3(b) states that the term “goods
put up in sets for retail sale” refers to goods that (a) consist of at least two different articles which are, prima
facie, classifiable in different headings; (b) consist of articles put up together to meet a particular need or
carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without
repacking. The subject merchandise fails to meet criteria (c) because the product must be assembled and
repackaged prior to shipment. See Headquarters Ruling H252291 (dated September 30, 2015). Therefore, the
steel load chain in its imported condition is considered a part of general use as described by Section XV.
The applicable subheading for the chain hoist body will be 8425.11.0000, HTSUS, which provides for
“Pulley tackle and hoists other than skip hoists; winches and capstans; jacks: Pulley tackle and hoists other
than skip hoists or hoists of a kind used for raising vehicles: Powered by electric motor.” The general rate of
duty will be free.
The applicable subheading for the steel load chain will be 7315.82.5000, HTSUS, which provides for “Chain
and parts thereof, of iron or steel: Other chain: Other, welded link: Of iron or nonalloy steel: Not over 10 mm
in diameter.” The general rate of duty will be free.
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)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division