CLA-2-84:OT:RR:NC:N1:102
Lawrence Friedman
Barnes, Richardson & Colburn, LLP
303 E Wacker Drive, Suite 305
Chicago, IL 60601
RE: The tariff classification of an active grille shutter from Thailand
Dear Mr. Friedman:
In your letter dated April 8, 2026, you requested a tariff classification ruling on behalf of your client, Ford
Motor Company.
The subject product is an active grille shutter, part number MB3B-8475-XX. The active grille shutter, which
is mounted behind the grill of a vehicle, consists of a structural plastic frame that incorporates multiple
movable louvers (shutter blades), an actuator assembly (12v DC brushed motor), an air deflector, a wiring
assembly, and a linkage mechanism connecting the actuator to all the louvers. The grille shutter also features
pivot points and bearings that allow each louver to rotate within the frame. When the grille shutter is
activated, it drives the linkage mechanism attached to each louver, causing all louvers to rotate
simultaneously between open, closed, or intermediate positions. The shutter is designed to be mounted in
front of the radiator and behind the bumper of a passenger vehicle.
The grille shutter is a dynamic product that operates in an entirely automatic manner and is controlled by the
vehicle’s electronic control unit (ECU), which is separately imported. The ECU adjusts the shutter position
based on real-time data such as engine temperature, vehicle speed, ambient air temperature, and engine load.
The ECU sends commands to the actuator, which adjusts the shutter to control airflow for aerodynamics or
cooling. In hotter temperatures or when the vehicle is under load such as towing, the shutter will open
allowing unlimited air to enter the engine bay. During freeway driving the shutter will close to prevent air
with debris from hitting the radiator and for better aerodynamics for fuel consumption.
In your letter, you suggest classifying the grille shutter in subheadings 8708.29, Harmonized Tariff Schedule
of the United States (HTSUS), which provides for vehicle body parts. Alternatively, you proposed
classification of the product in subheadings 8708.91, HTSUS, as parts of radiators or 8708.99, HTSUS, as
other parts and accessories of motor vehicles. To justify the classification in heading 8708, HTSUS, you cited
New York (NY) Rulings 850403, dated March 29, 1990; G89130, dated April 23, 2001; N024379, dated
March 18, 2008; N265868, dated August 23, 2015; and N349599, dated June 23, 2025.
Ruling 850403 describes the article as a “…radiator bug screen… comprised of a steel alloy screen, polyester
fabric, and eye grommets which fasten the bug screen to the front of a truck tractor. The article covers the
outside of the truck tractor radiator and is used to keep insects from clogging the radiator.” As can be seen
from the description, the article is different from the active grille at issue, since it contains no mechanical
elements.
Ruling G28130 describes the article as a “Front Grille: Sheet metal stamping.” No additional information is
mentioned. However, from the given information, this office can deduce that there are no mechanical features
in the front grille, unlike the active grille shutter at issue.
Ruling N024379 describes the product as “several pieces of metal netting used as cosmetic appliqués, as well
as functioning as a barrier to prevent debris or other small objects from entering into the bumper area and
damaging other parts inside the bumper area.” Once again, there are no mechanical features as described in
the grille shutters at issue.
Ruling N265868 describes the product as a garnish “…attached to the vehicle dashboard which controls the
direction and amount of heat and air conditioning within the vehicle. It is manually operated by either the
driver or passenger.” It clearly differs from the grille shutter at issue, as it does not contain any mechanical
components that control the airflow. If shut by the passenger, it renders absolutely no use.
Ruling N349599 describes the item as an air vent grill that “is a plastic injection-molded product assembled
into the vehicle ceiling and measures 118mm x 118mm x 26mm. It functions as a vent for the heater or air
conditioner, allowing manual opening/closing and adjustment of the airflow direction.” Here too, the item
differs from the grille shutter, as it is manually operated and has no mechanical features. Just like the garnish
in N265868, it has no utilitarian function if shut by the passenger.
In analyzing these rulings, CBP found the grille shutter to be operationally distinguishable from the items
described in rulings 850403, G28130, N024379, N265868, and N349599. These rulings pertain to items such
as radiator bug screens, sheet metal grilles, metal netting appliqués, dashboard garnishes, and manual air vent
grills, none of which possessed the mechanical, motor-actuated, and airflow-directing capabilities of the
active grille shutter. Furthermore, CBP has recognized grille shutters as valves classified within heading 8481
(NY Ruling Letter N334695, dated August 31, 2023), which is in agreement with the classification
determination of NY Ruling Letter F80523, dated February 10, 2000, which determined a damper door
system was operationally akin to a valve. The damper doors when assembled into a housing and are actuated
by mechanical cables or servomotors control airflow. In the same manner, the active grille shutter functions
as a motor-actuated valve, with louvers that rotate simultaneously to direct airflow for operational
enhancement.
Therefore, as valves and similar appliances are specifically provided for in heading 8481, HTSUS, they are
precluded from classification under subheadings 8708.29, 8708.91, and 8708.99, as per Note 2(e) to Section
XVII.
The applicable subheading for the active grille shutter, MB3B-8475-XX, will be 8481.80.9025, HTSUS,
which provides for Taps, cocks, valves and similar appliances…parts thereof: Other appliances: Other: Other:
With electrical or electro-hydraulic actuators: Other. The general rate of duty will be 2 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 Sandra Martinez, at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division