N349262

N349262 June 12, 2025 CLA-2-87:OT:RR:NC:N2 206 CATEGORY: Classification TARIFF NO.: 8708.94.7550; 9903.94.05; 9903.01.33 Man Je Kwak Onestop customs D-706-ho, 700, Pangyo-ro Bundang-gu, Seongnam-si 13516 South Korea RE: The tariff classification of steering coupler from South Korea Dear Mr. Kwak: In your letter dated May 21, 2025, you requested a tariff classification ruling on behalf of your client, HL Mando Corporation. The merchandise under consideration is identified as Damping Coupler, Part No: GM45302420, which is described as a flexible-type coupling composed of hubs and rubber plates. The coupler is designed to be used within a steering system in a vehicle. It is attached to the electric motor, which is then connected to the reduction gearbox within a steering system. You also referred to the component as shaft coupling, coupling or joint. In your submission, you suggest that the item is correctly classified under subheading 8483.60.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for transmission equipment. We disagree. The subject item is specifically designed to be used in a steering system of a vehicle. As a result, this item is precluded from classification under heading 8483 as per Note 1(l) to Section XVI, which excludes articles of Section XVII. The applicable subheading for the Damping Coupler, Part No: GM45302420, will be 8708.94.7550, HTSUS, which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Steering wheels, steering columns and steering boxes; parts thereof: Parts: Other: Other.” The general rate of duty will be 2.5 percent ad valorem. Effective May 3, 2025, Presidential proclamation 10908 imposed additional tariffs on certain automobile parts. Additional duties on automobile parts of 25 percent are reflected in Chapter 99, heading 9903.94.05, as provided in subdivision (g) of U.S. note 33 to this subchapter. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.94.05, in addition to subheading 8708.94.7550, HTSUS, listed above. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries will be subject to an additional 10 percent ad valorem rate of duty. Your product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.33, in addition to subheading 8708.94.7550, HTSUS, listed above. The tariffs and additional 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/. 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 liana.alvarez@cbp.dhs.gov. Sincerely, (for) Steven A. Mack Director National Commodity Specialist Division

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 liana.alvarez@cbp.dhs.gov. 
Sincerely,
 (for) Steven A. Mack Director National Commodity Specialist Division