N351601

N351601 July 28, 2025 CLA-2-87:OT:RR:NC:N2:201 CATEGORY: Classification TARIFF NO.: 8704.31.0120; 9903.94.04; 9903.01.25 Isaac Mendiola Mendiola Customs Brokerage 2112 S. Shary Rd, Suite 4 Mission, TX 78572 RE: The tariff classification of a 1999 Subaru Sambar light truck from Japan Dear Mr. Mendiola: In your letter dated July 23, 2025, you requested a tariff classification ruling. The item under consideration has been identified as a 1999 Subaru Sambar, a light-duty utility vehicle. The vehicle possesses the following features: 658cc (0.66 L) spark-ignition, internal combustion piston engine “Cab-over" chassis with a driver's cab Open rear cargo bed Gross Vehicle Weight Rating (GVWR): Approximately 1,200 kg (1.2 metric tons) Age: Over 25 years old In your request you suggest classification of the vehicle in 8704.31.0120, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Motor vehicles for the transport of goods: Other, with only spark-ignition internal combustion piston engine: G.V.W. not exceeding 5 metric tons: G.V.W. not exceeding 2.5 metric tons.” We concur. The applicable subheading for the 1999 Subaru Sambar will be 8704.31.0120, HTSUS, which provides for "Motor vehicles for the transport of goods: Other, with only spark-ignition internal combustion piston engine: G.V.W. not exceeding 5 metric tons: G.V.W. not exceeding 2.5 metric tons.”. The general rate of duty will be 25% ad valorem. Effective April 3, 2025, Presidential proclamation 10908 imposed additional tariffs on certain automobiles. Additional duties on passenger vehicles (sedans, sport utility vehicles, crossover vehicles, minivans or cargo vans) and light trucks of 25 percent, as provided in subdivision (b) of U.S. note 33 to this subchapter are reflected in Chapter 99, heading 9903.94.01. Certain passenger vehicles and light trucks manufactured in a year at least 25 years prior to the year of the date of entry, provided in heading 9903.94.04, are not subject to the additional duties. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.94.04, in addition to subheading 8704.31.0120, 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. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading 8704.31.0120, 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 Matthew Sullivan at matthew.sullivan@cbp.dhs.gov. Sincerely, (for) James Forkan Acting 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 Matthew Sullivan at matthew.sullivan@cbp.dhs.gov. 
Sincerely,
 (for) James Forkan Acting Director National Commodity Specialist Division