CLA-2-73:OT:RR:NC:N1:113

Arttu Viitasaari
Sleipner Finland Oy
Puistokatu 2A
Jyväskylä 40100
Finland

RE: The tariff classification of a wheeled excavator carrier from Finland

Dear Mr. Viitasaari:

In your letter dated March 17, 2026, you requested a tariff classification ruling. Technical material was submitted with your request.

The item under consideration is a wheeled excavator carrier, series designation Sleipner E50. It is a specialized, high-speed, wheel-based transport system designed to move 28 - 58 ton heavy duty tracked excavators around mining or quarry environments. When in use, a carrier is attached to the rear portion of the left and right tracks of the excavator. Once secured in place the excavator uses its boom and bucket to secure itself in the rear bed of an articulated dump truck (ADT) and lift the front portion of the tracks. Once the excavator is secure, the wheels on the carriers can move freely, letting the ADT tow the excavator to another location without the use of excavator’s tracks. It acts like a set of “roller skates,” allowing excavators to be pulled up to 15 kilometers an hour which reduces travel time and extends the life span of the tracks.

Each carrier is equipped with a steel track shoe and supported by two rubber tires. The frame of the shoe is in the shape of a scoop which allows the excavator’s track to roll into the shoe. It is flat on the bottom and bends vertically into two triangular shaped sides. Along the top of the shoe, both sides are joined together with a horizontal steel bar spanning the width of the shoe creating a gap between the bottom and the top. The outer face of each side is fitted with axles and hubs for the wheels. Each carrier is made up of 85% steel, and 15% rubber parts.

In your submission, you suggest the classification of the carrier be classified under subheading 8716.80, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Trailers and semi-trailers; other vehicles, not mechanically propelled; and parts thereof: Other vehicles.” We disagree. The Explanatory Notes (EN) to heading 8716 state, “this heading covers a group of non-mechanically propelled vehicles (other than those of the preceding headings) equipped with one or more wheels and constructed for the transport of goods or persons. It also includes non-mechanical vehicles not fitted with wheels (e.g., sledges, special sleds running on timber trackways).” The ENs also state, “the vehicles of this heading are designed to be towed by other vehicles (tractors, lorries, trucks, motorcycles, bicycles, etc.), to be pushed or pulled by hand, to be pushed by foot or to be drawn by animals.” This carrier does not fall into any of the categories of non-mechanically propelled vehicles given as exemplars. The carrier is not designed to be “towed by other vehicles, to be pushed or pulled by hand, to be pushed by foot or to be drawn by animals.” The carrier is used to add wheels to an excavator using its boom to secure itself in the rear bed of the ADT with the help of crushed rocks, or other appropriate material, as a result the machine i.e. excavator itself becomes the “trailer.” It is the opinion of this office that the wheeled excavator carrier is precluded from heading 8716, HTSUS.

We note that the carrier is composed of various materials. The classification of merchandise under the HTSUS is in accordance with the General Rules of Interpretation (GRIs), taken in order. GRI 3(b) provides that “mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale… shall be classified as if they consisted of the material or component which gives them their essential character.” EN VIII to GRI 3(b) explains that “the factor which determines essential character will vary as between different kinds of goods. It may, for example, be determined by the nature of the material or component, its bulk, quantity, weight or the use of the goods.” Since the carrier is composed of different materials and steel is the predominant material used, the carrier fits the description of a composite good with steel components imparting the essential character.

Heading 7326, HTSUS, is a residual or basket provision which covers a wide range of iron or steel articles that are not more specifically provided for elsewhere in the HTSUS. ENs to heading 7326, HTSUS, state that “This heading covers all iron or steel articles obtained by forging or punching, by cutting or stamping or by other processes such as folding, assembling, welding, turning, milling or perforating other than articles included in the preceding headings of this Chapter or covered by Note 1 to Section XV or included in Chapter 82 or 83 or more specifically covered elsewhere in the Nomenclature.” An article of iron or steel can be classified in heading 7326, HTSUS, if it is determined that the item is not more specifically provided for in any other heading of the tariff. The wheeled excavator carrier is not specifically covered elsewhere in the tariff. Accordingly, it is classifiable in heading 7326, HTSUS.

The applicable subheading for the wheeled excavator carrier will be 7326.90.8688, HTSUS, which provides for “Other articles of iron or steel: Other: Other: Other: Other: Other.” The general rate of duty will be 2.9 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 Matthew Gay at [email protected].
Sincerely,

(for)
James P. Forkan
Director
National Commodity Specialist Division