N353106

N353106 September 3, 2025 CLA-2-40:OT:RR:NC:N5:137 CATEGORY: Classification TARIFF NO.: 4009.32.0050. 8479.89.9599, 9903.01.24, 9903.01.25, 9903.02.20, 9903.88.03 Richard Rice Samoa Corporation 90 Monticello Rd Weaverville, NC 28787 RE: The tariff classification of hose reels with and without hoses from Spain or China Dear Mr. Rice: In your letter dated August 29, 2025, you requested a tariff classification ruling. The products under consideration are an aluminum retractable hose reel imported with an ethylene-propylene-diene (EPDM) hose (506 series) or separately, i.e. without the hose (504 series). Both the 504 and 506 Series reels are typically mounted in the ceiling of an automotive service center or garage, to move air or water-based fluids from a storage tank to an end point such as a car engine reservoir, radiator, or tires. The reels employ a spring-loaded ratchet mechanism to facilitate the retraction and dispensing to the hose. In operation, the hose is uncoiled by hand against the tension of the spring and can be locked in place by a latch mechanism. To recoil the hose, the user gently pulls the hose to release the latch, and the hose is automatically recoiled by the spring mechanism. Like the hose and reel combinations ruled upon in New York Ruling Letters N217149 and N271823, dated June 7, 2012, and February 2, 2016, respectively, the essential character of the hose reels incorporating the hose (506 series) is imparted by the hose. The applicable subheading for the hose reel incorporating an EPDM hose (506 series) will be 4009.32.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for tubes, pipes and hoses, of vulcanized rubber other than hard rubber, with or without their fittings: reinforced or otherwise combined only with textile materials: with fittings: other. The general rate of duty will be 2.5 percent ad valorem. The applicable subheading for the separately imported 504 Series reels will be 8479.89.9599, HTSUS, which provides for machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: other machines and mechanical appliances: other: other: other. The general rate of duty will be 2.5%. You indicate that the country of origin of these products may be Spain or China. Spain: 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 of the European Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15 percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General duty rate. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.20, in addition to subheading 4009.32.0050 or 8479.89.9599, HTSUS, listed above. China: Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition to subheading 4009.32.0050 or 8479.89.9599, 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 of China, Hong Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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 4009.32.0050 or 8479.89.9599, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 4009.32.0050 or 8479.89.9599, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 4009.32.0050 or 8479.89.9599, HTSUS, listed above. The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively. 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 Christina Allen at julie.c.allen@cbp.dhs.gov. Sincerely, (for) Denise Faingar 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 Christina Allen at julie.c.allen@cbp.dhs.gov. 
Sincerely,
 (for) Denise Faingar Acting Director National Commodity Specialist Division