CLA-2-N2:OT:RR:NC:N2:201
Calvin Oh
JAS USA
6165 Barfield Road
Atlanta, GA 30328
RE: The tariff classification of a hydraulic cylinder and actuator used for an agricultural seeder from Italy
Dear Mr. Oh:
In your letter dated February 3, 2026, you requested a tariff classification ruling on behalf of your client
Ognibene North America LLC.
The first article under consideration is a Hydraulic Cylinder - Ognibene P/N 995310040 (Deere P/N
AA114802) used for an Agricultural Seeder. You state that the hydraulic cylinder on an agricultural seeder
or planter is a crucial component that converts pressurized hydraulic fluid into linear mechanical force to
control the machine's depth, position, and operational state. It enables heavy-duty tasks to be performed with
precision, ensuring uniform seed placement for crop yield.
The second article under consideration is an Actuator - Ognibene P/N 995310080 (Deere P/N BU47768) used
for an Agricultural Seeder. You state it converts energy into precise mechanical motion to automate key
tasks, primarily controlling seeding depth, regulating seed/fertilizer dosage rates, and adjusting row markers.
It enhances accuracy in precision farming, reducing waste and optimizing crop yields while replacing
hydraulic systems with maintenance-free electric solutions. Modern systems use actuators to replace
mechanical springs, allowing them to adjust downforce in near real-time as soil conditions change across a
field. They precisely move dosing units to control the exact amount of seed or fertilizer dispensed, ensuring
the right dose with no wastage. They deploy and retract markers that designate furrow lanes, helping
operators maintain optimal seeding patterns.
In your letter, you propose that the servo-actuator is classified as a “part” of a an agricultural seeder under
subheading 8432.90.0060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for
agricultural, horticultural or forestry machinery for soil preparation or cultivation; lawn or sports ground
rollers; parts thereof: parts…other: of seeders, planters, transplanters, manure spreaders and fertilizer
spreaders. We disagree. The servo-actuator is specifically provided for elsewhere in Chapter 84.
“Parts” are classified in accordance with Note 2 to Section XVI which states that, subject to certain
exclusions found in Note 1 to Section XVI, Note 1 to Chapter 84 and Note 1 to Chapter 85, parts of machines
(not being parts of the articles of heading 8484, 8544, 8545, 8546 or 8547) are to be classified according to
the following rules:
(a) Parts which are goods included in any of the headings of chapters 84 and 85 (other than headings
8409, 8431, 8448, 8466, 8473, 8487, 8503, 8522, 8529, 8538 and 8548) are in all cases to be
classified in their respective headings…
Based on the technical information provided, the servo-actuator is specifically provided for within heading
8412, HTSUS.
The applicable subheading for the Hydraulic Cylinder - Ognibene P/N 995310040 and Actuator - Ognibene
P/N 995310080 will be 8412.29.8045, HTSUS, which provides for “Other engines and motors, and parts
thereof: Hydraulic power engines and motors: Other: Other: Unlimited rotary acting: Axial piston type.” The
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 the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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 Matthew Sullivan at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division