CLA-2-73:OT:RR:NC:N5:116
Vishal Shah
USUI International Corporation
3824 Cook Blvd.
Chesapeake, VA 23518
RE: The tariff classification of high-pressure diesel fuel injection tubes from Japan
Dear Mr. Shah:
In your letter dated April 9, 2026, you requested a tariff classification.
The products under consideration are identified as high-pressure diesel fuel injection tubes from Japan. These
seamless, cold-rolled, alloy steel tubes have an inside diameter of 3 mm and an outside diameter of 8 mm.
Based on the molybdenum content, the tubes meet the definition of an other alloy steel in accordance with
Chapter 72, Note 1(f), Harmonized Tariff Schedule of the United States (HTSUS).
Consideration was given to classifying the high-pressure diesel fuel injection tubes, Parts Numbers
80X30X3410SP1H, 80X30X3130S850, and 80X30X3110S900, in subheading 8708.99.6890, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for motor vehicles power train parts and
accessories, as you suggested. We disagree. In their condition as imported, the tubes are not yet identifiable
as automotive components and do not possess any features that render them their sole use in automotive
applications. It is only after the processes in the United States that the tubes become identifiable as fuel
injection tubes. Furthermore, the tubes are not components of vehicle power trains as they do not provide
torque or contribute to any moving parts of the vehicle. They are simply conduits. Additionally, tubes are
specifically provided for elsewhere in the tariff. Additional U.S Rule of Interpretation 1(c) states that in the
absence of special language or context which otherwise requires, a provision for parts of an article covers
products solely or principally used as a part of such articles but a provision for “parts” or “parts and
accessories” shall not prevail over a specific provision for such part or accessory. As a result, classification of
the tubes, Parts Numbers 80X30X3410SP1H, 80X30X3130S850, and 80X30X3110S900, in subheading
8708.99.6890, HTSUS, is precluded.
The applicable subheading for the high-pressure diesel fuel injection tubes will be 7304.51.5060, HTSUS,
which provides for tubes, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel, other, of
circular cross section, of other alloy steel, cold-drawn or cold-rolled (cold-reduced), other, other, other. The
general rate of duty will be free.
Please be advised that alloy steel tubing from Japan may be subject to antidumping duties and/or
countervailing duties (AD/CVD). Written decisions regarding the scope of AD/CVD orders are issued by the
Enforcement and Compliance office in the International Trade Administration of the Department of
Commerce (ITA) and are separate from tariff classification and origin rulings issued by Customs and Border
Protection (CBP). General information regarding the ITA and AD/CVD can be found at
https://www.trade.gov/us-antidumping-and-countervailing-duties. The ITA’s “Guide on How to File for an
Antidumping/Countervailing Duty Scope Ruling Request” is available at
https://enforcement.trade.gov/scope/Request-Scope-Ruling.pdf.
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/current.
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 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 above, contact
National Import Specialist Neil M. Cohen at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division