H350291

H350291 July 16, 2026 OT:RR:CTF:VS H350291 JH CATEGORY: Origin Jae Chung President QS Customs Brokers, Inc. 2020 Piper Ranch Rd, San Diego, CA 92154-0000 RE: Country of Origin Marking; USMCA; Unassembled Cargo Container Dear Mr. Chung: This is in response to your July 10, 2025 ruling request, filed on behalf of Hyundai Translead San Diego (or “importer”), regarding the classification, eligibility for preferential tariff treatment under the United States-Mexico-Canada Agreement (“USMCA”), and country of origin marking of the Hyundai unassembled cargo container. FACTS: In Headquarters Ruling Letter (HQ) H341684, issued to you on July 10, 2025, the USMCA eligibility, country of origin marking, and classification for the same cargo container was addressed. However, for this ruling, the importer is producing an unassembled version of the same cargo container for use with heavy trucks. The unassembled cargo container is to be sold as an aftermarket part for heavy trucks. The components of the unassembled cargo container are produced in Mexico (Tijuana and Rosarito), and are shipped to the United States to be later assembled in the U.S. The unassembled cargo container consists of the following components: • Front Wall Assembly, • Top Rail, • Bottom Rail, • Rear Frame Assembly and Installation, • Side Wall Assemblies, • Floor Assembly, • Roof Assembly & Installation, 2 • Rear Door Installation, and • Electrical Harness. In Mexico, side composite panels and side posts are put together with the rail attachments (top and bottom rail) to make the side wall assemblies. The rail attachments are stated to be a product of the U.S., and the side posts are either a product of Mexico or the U.S. The side composite panels are a product of Mexico, and the same material is used for the front wall. For the roof assembly, the roof is rolled onto the cargo container with the assistance of the roof bows that are drilled onto the side top rails. Both the roof and the roof bows are products of the U.S. For the rear frame assembly, the frame is secured onto the floor and base assembly. The rear frame is predominantly made up of non-USMCA material. The rear door that is secured onto the rear frame is a product of the U.S. For the floor assembly, the upper coupler, crossmembers, and rear threshold plate are assembled onto a wood floor. The wood floor and crossmembers are a product of the U.S., while the rear threshold and upper coupler are a product of Mexico. For the electrical harness, it is secured and attached onto the bottom of the cargo container and made ready to connect necessary electrical components to the cargo container. The electrical harness contains U.S. and Mexican components. All of the nonoriginating materials used in the production of the components are stated to be classifiable outside of heading 8707. Along with the parts for the unassembled cargo container, additional hardware (also originating from USMCA and non-USMCA countries) consisting of washers, nuts, bolt brackets, mud flap bracket/retainers, mud flaps, HH bolts, H lock nuts, washer fenders, space fillers, and the rear bumper assembly are shipped to be used for the truck body assembly. The unassembled cargo container and the additional hardware are shipped to authorized dealers in the U.S. (California, Texas, Michigan, Georgia, Utah, Illinois, Pennsylvania) who will assemble the cargo container, and then assemble the cargo container onto the truck body assembly for use in heavy trucks. ISSUES: What is the tariff classification of the unassembled cargo container? What is the country of origin for marking purposes of the unassembled cargo container? Whether the unassembled cargo container is eligible for USCMA preferential tariff treatment? 3 LAW AND ANALYSIS: Classification Classification under the HTSUS is made in accordance with the General Rules of Interpretation (“GRIs”). GRI 1 provides that classification shall be determined first according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may be applied in order. GRI 2(a) provides as follows: Any reference in a heading to an article shall be taken to include a reference to that article incomplete or unfinished, provided that, as presented, the incomplete or unfinished article has the essential character of the complete or finished article. It shall also be taken to include a reference to that article complete or finished (or falling to be classified as complete or finished by virtue of this rule), presented unassembled or disassembled. The Explanatory Notes of the Harmonized Commodity Description Coding System (“ENs”) constitute the official interpretation of the Harmonized System. While not legally binding nor dispositive, the ENs provide a commentary on the scope of each heading of the Harmonized System and are generally indicative of the proper interpretation of these headings. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989). EN 87.07 states, in relevant parts that “[t]his heading covers bodies (including cabs) for the motor vehicles of headings 87.01 to 87.05.” The unassembled cargo container is eo nomine classified under heading 8707, HTSUS, which provides for “[b]odies (including cabs), for the motor vehicles of headings 8701 to 8705” by application of GRI 1 if entered as a complete good or by application of GRI 2(a) if entered as an unassembled kit. Given the cargo container will be used in vehicles for the transport of goods of heading 8704, HTSUS, the unassembled cargo container is classifiable by application of GRI 6 under subheading 8707.90.50, HTSUS, which provides, in relevant part, for “other bodies for vehicles of heading 8704.” Country of Origin Marking The marking statute, Section 304, Tariff Act of 1930, as amended (19 U.S.C.§ 1304), provides that, unless excepted, every article of foreign origin (or its cargo container) imported into the United States shall be marked in a conspicuous place as legibly, indelibly and permanently as the nature of the article (or its cargo container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States the English name of the country of origin of the article. Part 134 of the U.S. Customs and 4 Border Protection (“CBP”) Regulations (19 C.F.R. Part 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. § 1304. Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other USMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in §§ 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect to goods imported from Canada and Mexico. Title 19, C.F.R. § 102.11(a) provides that the country of origin of a good is the country in which: (1) The good is wholly obtained or produced; (2) The good is produced exclusively from domestic materials; or (3) Each foreign material incorporated in that good undergoes an applicable change in tariff classification set out in § 102.20 and satisfies any other applicable requirements of that section, and all other applicable requirements of these rules are satisfied. “Foreign material” is defined in 19 C.F.R. § 102.1(e) as “a material whose country of origin as determined under these rules is not the same country as the country in which the good is produced.” Here, sections 102.11(a)(1) and 102.11(a)(2) do not apply because the product will neither be wholly obtained or produced nor produced exclusively from “domestic” (Mexican, in this case) materials. Accordingly, each non-Mexican material must meet the applicable change in tariff classification set out in Section 102.20 in order for the product to qualify to be marked as a product of Mexico. Purs

Classification Classification under the HTSUS is made in accordance with the General Rules of Interpretation (“GRIs”). GRI 1 provides that classification shall be determined first according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may be applied in order. GRI 2(a) provides as follows: Any reference in a heading to an article shall be taken to include a reference to that article incomplete or unfinished, provided that, as presented, the incomplete or unfinished article has the essential character of the complete or finished article. It shall also be taken to include a reference to that article complete or finished (or falling to be classified as complete or finished by virtue of this rule), presented unassembled or disassembled. The Explanatory Notes of the Harmonized Commodity Description Coding System (“ENs”) constitute the official interpretation of the Harmonized System. While not legally binding nor dispositive, the ENs provide a commentary on the scope of each heading of the Harmonized System and are generally indicative of the proper interpretation of these headings. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989). EN 87.07 states, in relevant parts that “[t]his heading covers bodies (including cabs) for the motor vehicles of headings 87.01 to 87.05.” The unassembled cargo container is eo nomine classified under heading 8707, HTSUS, which provides for “[b]odies (including cabs), for the motor vehicles of headings 8701 to 8705” by application of GRI 1 if entered as a complete good or by application of GRI 2(a) if entered as an unassembled kit. Given the cargo container will be used in vehicles for the transport of goods of heading 8704, HTSUS, the unassembled cargo container is classifiable by application of GRI 6 under subhead