CLA-2-87:OT:RR:NC:N2:206
Brian Busse
Means Industries Inc.
3715 E Washington Rd.
Saginaw, MI 48601
RE: The tariff classification of a clutch from Canada
Dear Mr. Busse:
In your letter dated March 24, 2026, you requested a tariff classification ruling.
The article under consideration is a clutch, Part Number 15568, which is designed to be used in automatic
transmissions of passenger vehicles. The clutch is primarily used to connect and disconnect power once
actuated via the solenoid. A speed sensor assembly is also a component within the clutch. The 15568 clutch
requires the use of fluid coupling and automatic control actuation controlled by a solenoid. It is used in
conjunction with other automatic transmission internal components to cause the gear speed setting of the
automatic transmission to change for higher speeds or for lower speeds. These automatic transmissions have
gears defined as Park, Reverse, and Drive. Within Drive, anywhere from four to six gear, or speed settings
are in place within the automatic transmission to accommodate a speed range for highway, city, or off-road.
These speeds are set in part by the subject merchandise working in conjunction with the other automatic
transmission components.
The clutch contains an inner race and outer race that are both made from sintered powdered metal. The
internal parts are steel. Internally, there are steel struts that only allow the inner race to rotate in one direction.
The outer race is fixed to the inside of the transmission case, while the inner race is able to rotate in one
direction. The component that is keyed/splined to the inner race can rotate freely in the counter-clockwise
direction, allowing the transmission to engage any gear but 1st or reverse.
With no change to the clutch settings, other internal transmission components are engaged causing parts
through the inside of the clutch to attempt clockwise rotation which is prevented by the clutch engagement.
This results in the transmission engaging 1st gear. A solenoid actuator via a rocker assembly can lock
rotation in the counter-clockwise direction and allows the transmission to engage reverse gear.
In both directions the “locking” is controlled by steel tabs (struts) that act similarly to a conventional ratchet.
In one direction the ramps will click past the struts and in the other direction the struts catch the ramps. The
struts that prevent clockwise rotation are always engaged with the solenoid through a rocker to actuate the
struts that lock/prevent counter-clockwise rotation. The solenoid is DC powered by the vehicle battery
system.
In your submission, you state that the subject clutch component is not classified under subheading
8505.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for
“Electromagnets; permanent magnets and articles intended to become permanent magnets after
magnetization; electromagnetic or permanent magnet chucks, clamps and similar holding devices;
electromagnetic couplings, clutches and brakes; electromagnetic lifting heads; parts thereof: Electromagnetic
couplings, clutches and brakes.” We agree. While the clutch component does incorporate a solenoid, its
function is limited to enabling the transmission to engage reverse gear. During normal operation, the clutch
component relies on fluid coupling within the automotive transmission case to engage the gears. Therefore,
classifying the clutch component in heading 8505 would not be appropriate.
The applicable subheading for the clutch, Part Number 15568, will be 8708.93.6000, HTSUS, which
provides for “Parts and accessories of the motor vehicles of Headings 8701 to 8705: Other parts and
accessories: Clutches and parts thereof: For other vehicles: Clutches.” The general rate of duty will be 2.5
percent ad valorem.
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 Liana Alvarez at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division