N356859

N356859 December 29, 2025 CLA-2-84:OT:RR:NC:N1:103 CATEGORY: Classification TARIFF NO.: 8479.89.9599; 8425.39.0100; 8425.31.0100 Kyle Down Timberland Equipment Limited 459 Industrial Avenue Woodstock, Ontario N4S 7Z2 Canada RE: The tariff classification of a cable scrapper, a reel winder, and drum pullers from Canada Dear Mr. Down: In your letter dated December 9, 2025, you requested a tariff classification ruling. The first item is identified as a cable scrapper, item 30-00587-000, and is described as a skid-mounted hydraulically powered industrial machine that removes old communication and power cables from underground ducts while simultaneously cutting (shearing) them into manageable scrap lengths. It employs a hydraulic capstan to pull out the old cables and features a mounting base, a hydraulic-cylinder mounted pulling frame attached to an articulated/telescopic boom to guide the cable, an automated shearing system, and a control panel. The cable scrapper is composed of steel. In your submission, you suggest that the cable scrapper is classifiable in subheading 8479.89.95. As indicated below, we agree. The second item is identified as a drum puller, model number DP100, and is described as a single drum puller for electric utility work that is mounted on a towable open trailer. It is used to pull heavy electrical conductors such as wires through conduits and underground pathways, or onto transmission towers and poles. It has a drum that is driven by two hydraulic drives, which are composed of variable axial piston motors, a hydraulic holding brake, a planetary reducer, and a chain drive. This puller is powered by a 173-horsepower diesel engine. The third item is identified as an electric drum puller, model number DPT40E, whose function is identical to the DP100 described above. Instead of containing a diesel engine, it is powered by a 96-volt rechargeable battery bank which drives a 50-horsepower electric motor. The last item is identified as a reel winder, model RW70-1-H, and is used in tandem with a trailer-mounted bull wheel pull-tensioner (not imported here) for controlled winding. The reel winder consists of a base frame, adjustable rollers, its own drive system (consisting of a chained sprocket to rotate the reels, a hydraulic motor, and a gear box), and hydraulic hoses to connect to the pull-tensioner. The reel winder is designed for spooling large reels of wire rope, cable or hose, and provides the storage capacity and the minimum tail line tension required by the pull-tensioner. You suggest the reel winder is classifiable in subheading 8425.39 as a pulling and lifting device. We disagree. The purpose of the reel winder is not to pull, lift, haul, or act upon another object, but to coil and store wire rope as it comes off the bull wheel pull-tensioner. As such, heading 8425 is not appropriate. The applicable subheading for both the cable scrapper, item 30-00587-000, and the reel winder, model RW70-1-H, will be 8479.89.9599, Harmonized Tariff Schedule of the United States (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 is 2.5 percent ad valorem. The applicable subheading for the drum puller, model number DP100, will be 8425.39.0100, HTSUS, which provides for “Pulley tackle and hoists other than skip hoists; winches and capstans; jacks: Winches; capstans: Other.” The general rate of duty will be free. The applicable subheading for the electric drum puller, model number DPT40E, will be 8425.31.0100, HTSUS, which provides for “Pulley tackle and hoists other than skip hoists; winches and capstans; jacks: Winches; capstans: Powered by electric motor.” The general rate of duty will be free. The 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on the Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ. 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 Paul Huang at paul.huang@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division

brake, a planetary reducer, and a chain drive. This puller is powered by a 173-horsepower diesel engine. The third item is identified as an electric drum puller, model number DPT40E, whose function is identical to the DP100 described above. Instead of containing a diesel engine, it is powered by a 96-volt rechargeable battery bank which drives a 50-horsepower electric motor. The last item is identified as a reel winder, model RW70-1-H, and is used in tandem with a trailer-mounted bull wheel pull-tensioner (not imported here) for controlled winding. The reel winder consists of a base frame, adjustable rollers, its own drive system (consisting of a chained sprocket to rotate the reels, a 

hydraulic motor, and a gear box), and hydraulic hoses to connect to the pull-tensioner. The reel winder is designed for spooling large reels of wire rope, cable or hose, and provides the storage capacity and the minimum tail line tension required by the pull-tensioner. You suggest the reel winder is classifiable in subheading 8425.39 as a pulling and lifting device. We disagree. The purpose of the reel winder is not to pull, lift, haul, or act upon another object, but to coil and store wire rope as it comes off the bull wheel pull-tensioner. As such, heading 8425 is not appropriate. The applicable subheading for both the cable scrapper, item 30-00587-000, and the reel winder, model RW70-1-H, will be 8479.89.9599, Harmonized Tariff Schedule of the United States (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 is 2.5 percent ad valorem. The applicable subheading for the drum puller, model number DP100, will be 8425.39.0100, HTSUS, which provides for “Pulley tackle and hoists other than skip hoists; winches and capstans; jacks: Winches; capstans: Other.” The general rate of duty will be f