CLA-2-84:OT:RR:NC:N2:206
Mike Kim
K&G Customs Service Inc
5935 Buford Highway, Suite 300 Norcross, GA 30071
RE: The tariff classification of engine parts from South Korea
Dear Mr. Kim:
In your letter dated October 17, 2024, you requested a tariff classification ruling on engine parts, which you filed on behalf of your client, DYP AL Inc. Pictures and other descriptive literature were submitted with your request.
The products under consideration are five separate engine parts that include the piston, connecting rod, a pin, rings, and snap ring. The piston is made from steel and converts the reciprocating (up-and-down) motion in the engine down to the crankshaft through the connecting rod. The connecting rod connects the piston to the crankshaft, and together with the crank, forms a simple mechanism that converts reciprocating motion into the rotary motion of the crankshaft. The three rings (top ring, second ring, and oil ring) perform roles including locking in the explosive power inside the combustion chamber, closing space between the piston and cylinder wall, and maintaining engine oil. The pin is made from a steel-chromium-molybdenum alloy and it connects the piston to the connecting rod. The snap ring is made from high carbon steel and its purpose is to prevent the relative movement of parts. In subsequent correspondence, you stated that the parts will be used in spark-ignition engines for passenger vehicles.
The applicable subheading for the connecting rod will be 8409.91.5010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Parts suitable for use solely or principally with the engines of heading 8407 or 8408: Other: Suitable for use solely or principally with spark-ignition internal combustion piston engines (including rotary engines): Other: To be installed in vehicles of subheading 8701.21, 8701.22, 8701.23, 8701.24 or 8701.29, or heading 8702, 8703 or 8704: Other: Connecting rods. The general rate of duty will be 2.5 percent ad valorem.
The applicable subheading for the piston, pin, rings, and snap ring will be 8409.91.5085, HTSUS, which provides for Parts suitable for use solely or principally with the engines of heading 8407 or 8408: Other: Suitable for use solely or principally with spark-ignition internal combustion piston engines (including rotary engines): Other: To be installed in vehicles of subheading 8701.21, 8701.22, 8701.23, 8701.24 or 8701.29, or heading 8702, 8703 or 8704: Other: Other. The general rate of duty will be 2.5 percent ad valorem.
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 [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division