N349663

N349663 July 1, 2025 CLA-2-87:OT:RR:NC:N:2:206 CATEGORY: Classification TARIFF NO.: 8708.80.6590; 9903.94.05; 9903.01.33 Changgyu Kim SEIN Customs & Auditing Corp 138, Seoun-ro, Seocho-gu, Seoul 06619 South Korea RE: The tariff classification of seal carriers from South Korea Dear Mr. Kim: In your letter dated May 31, 2025, you requested a tariff classification ruling on behalf of your client, Daeheung R&T Co., Ltd. The articles under consideration are seal carriers: Seal Cap (Part Number 72-3582-1866), Carrier Sealing (Part Number 72-3582-5670), and Carrier Sealing (Part Number 72-3582-5691), which are designed for electric vehicles. The seal carriers are coupled at the bottom of the air spring within the vehicle’s air suspension tower. By sealing air, they contribute to maintaining the air suspension system’s pressure and ensuring its normal operation. The seal carriers are made of 100 percent aluminum alloy and measure 82 x 24.8 mm, 106 x 25 mm, and 92 x 29 mm, respectively. You proposed classifying the seal carriers in subheading 8708.99.8180, Harmonized Tariff Schedule of the United States (HTSUS), as other vehicle parts and accessories. You also state that the seal carriers cannot be considered for classification in subheading 8708.80, HTSUS, which provides for suspension systems and parts, because they are not principal components like 'suspension systems' or 'shock absorbers' as stipulated in 8708.80. We disagree. Subheading 8708.80, HTSUS, provides not only for suspension systems and shock absorbers, but also for parts. You refer to them as “auxiliary” parts that seal the air inside the air spring because they do not directly provide the primary damping or supporting functions of the air suspension system. However, the seal carriers perform a sealing role to prevent air from leaking externally, thereby enabling the air spring to fully function. They are essential components required for the normal operation of the air spring. As a result, they meet the CBP definition of a part and will be classified as parts of suspension systems. The applicable subheading for the seal carriers: Seal Cap (Part Number 72-3582-1866), Carrier Sealing (Part Number 72-3582-5670), and Carrier Sealing (Part Number 72-3582-5691) will be 8708.80.6590, HTSUS, which provides for “Parts and accessories of the motor vehicles of heading 8701 to 8705: Suspension systems and parts thereof (including shock absorbers): Parts: Other: 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 8708.80.6590, 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 8708.80.6590, 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, 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 Liana Alvarez at liana.alvarez@cbp.dhs.gov. 
Sincerely,
 James Forkan Acting Director National Commodity Specialist Division