H348950

H348950 October 17, 2025 OT:RR:CTF:EMAIN H348950 SKK CATEGORY: Classification TARIFF NO.: 8432.90.00 Benjamin Shanbaum Rock Trade Law LLC 134 N. LaSalle St. Chicago, IL 60602 RE: Ruling request concerning the tariff classification of wheel and tire assemblies for use in lawn and garden spreaders Dear Mr. Shanbaum: This is in response to your ruling request, dated April 1, 2025, submitted on behalf of the importer Agri-Fab, Inc., to our National Commodity Specialist Division, which forwarded your request to this office. You seek a determination as to the classification under the Harmonized Tariff Schedule of the United States (“HTSUS”) of certain wheel and tire assemblies that will be used in the manufacture of tow-behind and walk-behind lawn and garden spreaders (model numbers 45702Y, 45802G, 45825G, 48511G, 40880G, 40880Y, 40939G, and 45702G), as well as their eligibility for duty-free treatment under heading 9817.00.60, HTSUS.? No sample was provided for examination. FACTS: The subject articles are wheel and tire assemblies used in the manufacture of tow-behind and walk-behind lawn and garden spreaders. These products consist of a welded steel hub and rim, a bearing or bushing that may be composed of steel or ABS plastic, and a tube-type rubber tire. These assemblies are imported from China. The specific wheel models the subject of this ruling are described below. ? We note that the potential applicability of heading 9817.00.60, HTSUS, was addressed under separate cover. This letter addresses the classification of the subject merchandise under Chapters 1-97 of the HTSUS. • Model 45702Y: This model consists of a steel wheel rim with a welded steel hub, a steel bearing, and a pneumatic tube-type rubber tire. The wheel, painted yellow, has a nominal diameter of 4 inches. When fully inflated, the tire has a diameter of 10 inches and a width of 3.5 inches. The assembled hub and bearing have a width of 2.16 inches. The tire is not rated for on-highway use. This wheel is used in the production of lawn and garden spreaders. • Model 45802G: This model consists of a steel wheel rim with a welded steel hub, a steel bearing, and a pneumatic tube-type rubber tire. The wheel, which is painted gray, has a nominal diameter of 172 mm (approximately 6.77 inches). When fully inflated, the tire has a diameter of 302 mm (approximately 11.89 inches) and a width of 105 mm (approximately 4.13 inches). The assembled hub and bearing have a width of 54.8 mm (approximately 2.16 inches). The tire is not rated for on-highway use. • Model 45825G: This model consists of a steel wheel rim with a welded steel hub, a steel bearing, and a pneumatic tube-type rubber tire. The wheel, which is painted gray, has a nominal diameter of 6 inches. When fully inflated, the tire has a diameter of 13 inches and a width of 5 inches. The assembled hub and bearing have a width of 3.5 inches. The tire is not rated for on-highway use. • Model 48511G: This model consists of a steel wheel rim with a welded steel hub, a steel bearing, and a pneumatic tube-type rubber tire. The wheel, which is painted gray, has a nominal diameter of 175 mm (approximately 6.89 inches). When fully inflated, the tire has a diameter of 351 mm (approximately 13.82 inches) and a width of 129 mm (approximately 5.08 inches). The assembled hub and bearing have a width of 113.5 mm (approximately 4.47 inches). The tire is not rated for on-highway use. ISSUE: What is the proper tariff classification of the subject wheel assemblies under the HTSUS? LAW AND ANALYSIS: Classification under the HTSUS is in accordance with the General Rules of Interpretation (GRIs) and any applicable legal notes. GRI 1 requires that classification be determined first according to the terms of the headings of the tariff schedule and any relative section or chapter notes. If goods cannot be classified solely on the basis of GRI 1, and if the heading and legal notes do not otherwise require, the remaining GRIs 2 through 6 may then be applied in order. 2 The HTSUS provisions under consideration are as follows: 8432 Agricultural, horticultural or forestry machinery for soil preparation or cultivation; lawn or sports ground rollers; parts thereof: * * * * * 8432.90.00 Parts The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official interpretation of the Harmonized System at the international level. While neither legally binding nor dispositive, the ENs provide a commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of the headings. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989). The EN for heading 8432 provides, in pertinent part,: This heading covers machines, whatever their mode of traction, used in place of hand tools, for one or more of the following classes of agricultural, horticultural or forestry work, viz.: * * * * * (II) Spreading or distributing fertilizers, including manure, or other products to improve the soil. The subject wheel and tire assemblies are used in the manufacture of tow-behind and walk-behind lawn and garden spreaders. As lawn and garden spreaders are used to broadcast grass seed, fertilizer, and herbicide over a lawn or garden for purposes of improving or preparing the soil, they are provided for in heading 8432, HTSUS, as horticultural machinery for soil preparation or cultivation. This conclusion is supported by the ENs to heading 84.32, supra. In considering the question of whether the subject wheel and tire assemblies are parts of horticultural machinery for soil preparation or cultivation, the courts have examined the meaning of “parts” for purposes of classification under the HTSUS, resulting in two distinct, though not inconsistent, tests. See Bauerhin Technologies Limited Partnership, and John V. Carr & Sons Inc., v. United States, 110 F.3d 774 (Fed. Cir. 1997), citing United States v. Willoughby Camera Stores, Inc., 21 C.C.P.A. 322 (1933), and United States v. Pompeo, 43 C.C.P.A. 9 (1955). In Bauerhin, citing Willoughby Camera, the court held that “the mere fact that two articles are designed and constructed to be used together, does not necessarily make either a part of the other” and that the threshold question is whether an item “is an integral, constituent, or component part, without which the article to which it is to be joined, could not function as such article.” Willoughby Camera, 21 C.C.P.A. at 324. In United States v. Pompeo, the court stated that an imported item dedicated solely for use with another article is a part of that article provided that, when applied to that use, the article will not function without it. Pompeo, 43 C.C.P.A at 14. CBP generally will consider an article to be a part if it is an integral constituent or component without which the article to which it is joined could not function. As horticultural spreaders are designed to be mobile to be able to distribute their contents over an area of soil, they require some means of traction to enable movement. The subject wheel and tire assemblies 3 provide horticultural spreaders with the requisite mobility to perform their intended function. As such, the subject wheel and tire assemblies are “parts” or horticultural machinery for soil preparation or cultivation and classified under subheading 8432.90.00, HTSUS. This determination is consistent with New York Ruling Letter (NY) N305062, dated July 19, 2019, in which U.S. Customs and Border Protection classified wheel assemblies intended for installation onto fertilizer spreaders under subheading 8432.90.00, HTSUS. See also NY N306401, dated October 10, 2019, in which CBP classified a wheel hub for a motorized turf aerator under subheading 8432.90.00, HTSUS. HOLDING: By application of GRIs 1 and 6, the subject wheel and tire assemblies (identified as Models 45702Y, 45802G, 45825G and 48511G) are classified under statistical reporting number 8432.90.00, HTSUS, which provides for “[A]gricult

Classification under the HTSUS is in accordance with the General Rules of Interpretation (GRIs) and any applicable legal notes. GRI 1 requires that classification be determined first according to the terms of the headings of the tariff schedule and any relative section or chapter notes. If goods cannot be classified solely on the basis of GRI 1, and if the heading and legal notes do not otherwise require, the remaining GRIs 2 through 6 may then be applied in order. 2 

The HTSUS provisions under consideration are as follows: 8432 Agricultural, horticultural or forestry machinery for soil preparation or cultivation; lawn or sports ground rollers; parts thereof: * * * * * 8432.90.00 Parts The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official interpretation of the Harmonized System at the international level. While neither legally binding nor dispositive, the ENs provide a commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of the headings. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989). The EN for heading 8432 provides, in pertinent part,: This heading covers machines, whatever their mode of traction, used in place of hand tools, for one or more of the following classes of agricultural, horticultural or forestry work, viz.: * * * * * (II) Spreading or distributing fertilizers, including manure, or other products to improve the soil. The subject wheel and tire assemblies are used in the manufacture of tow-behind and walk-behind lawn and garden spreaders. As lawn and garden spreaders are used to broadcast grass seed, fertilizer, and herbicide over a lawn or garden for purposes of improving or preparing the soil, they are provided for in heading 8432, HTSUS, as horticultural machinery for soil preparation or cultivation. This conclusion is supported by the ENs to heading 84.32, supra. In considering the question of whether the subject wheel and tire as