CLA-2-:OT:RR:NC:N2:201
Thomas Gilchrist
On-Crane Solutions LLC
26 Ringfield Road
Chadds Ford, PA 19317
RE: The tariff classification of fixed gooseneck trailers from Poland
Dear Mr. Gilchrist:
In your letter dated February 24, 2026, you requested a tariff classification ruling on behalf of your client, NT
Industry (DBA Novatech APS), located in Aalborg, Denmark.
The submission concerns fixed gooseneck industrial roll trailers identified as the RT-Series, including models
:
RT60
RT80
RT100, and
RT120
You state that variations among RT-Series models relate solely to payload capacity and dimensional scaling
and do not alter construction, operational characteristics, or principal use.
These trailers are designed exclusively for transportation of ISO containers and industrial cargo within
marine terminals, ports, steel facilities, and other controlled industrial environments when towed by external
tractor units.
You state that the RT-Series roll trailers function solely as passive cargo transport platforms. All cargo
handling operations are performed exclusively by external equipment. The trailers:
Do not lift cargo,
Do not load or unload cargo
Do not elevate cargo
Do not stack or position cargo
Do not secure cargo through powered mechanisms
Perform no industrial processing function
You state that each trailer incorporates the following common features:
Fixed gooseneck assembly
2” or 3.5” kingpin towing connection
Skeletal I-beam structural chassis (ST355 steel)
Steel cargo deck platform
ISO container positioning capability
D-ring lashing systems
Multi-axle running gear
Solid rubber industrial tires
RT60 RT80 RT100
Size (LxWxH) 14.500 × 2.500 × 1.250 14.500 × 2.500 × 1.250 14.500 × 2.500 × 1.
Loading Deck Height 800 mm 800 mm 800 mm
Capacity 60 Ton 80 Ton 100 Ton
Wheel Size 22×12×16” 22×14×16” 22×16×16”
In your request you suggest classification of the RT-Series of roll trailers in 8716.39.0090, Harmonized
Tariff Schedule of the United States (HTSUS) which provides for semi-trailers. We agree.
The applicable subheading for the RT-Series (RT60, RT80, RT100, and RT120) fixed gooseneck trailers will
be 8716.39.0090, HTSUS, which provides for “Trailers and semi-trailers; other vehicles, not mechanically
propelled; and parts thereof: Other trailers and semi-trailers for the transport of goods: Other: Other: Other.”
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 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