CLA-2-84:OT:RR:NC:N1:103
David Parker Bennett Int'l. Transport LLC 1001 Industrial Pkwy. McDonough, GA 30253 RE: The tariff classification of a pivot pin and bushing from India Dear Mr. Parker: In your letter dated February 26, 2025, you requested a tariff classification ruling on behalf of your client, Industrial Products International, Inc. The first item under consideration is referred to as a pivot pin, part number 4231206, described as a component of a pin assembly for a front-end shovel loader. A pin assembly consists of a pivot pin and two saw cut bushings, and is used to secure a bucket to the boom of a front-end shovel loader. The pivot pin is described as a cylindrical rod-like pin with beveled ends. It is machined from hot rolled steel bar stock and measures approximately 11 inches in length, 6.7 inches in diameter, and weighs 86 pounds. The second item under consideration is referred to as a steel saw cut bushing, part number 4231207, and described as the second component in a pin assembly. The saw cut bushing is a tapered circular bushing with a slit running along its length. The slit allows the bushing to expand when it is installed onto a joint. Based on the submitted drawings, the bushing resembles a trapezoidal cone and weighs approximately 10 pounds. In your request, you suggest the pivot pin and saw cut bushing are classified in heading 8431, Harmonized Tariff Schedule of the United States (HTSUS). We agree. The applicable subheading for the pivot pin, part number 4231206, and the saw cut bushing, part number 4231207, will be 8431.49.9095, HTSUS, which provides for “Parts suitable for use solely or principally with the machinery of headings 8425 to 8430: Of machinery of heading 8426, 8429 or 8430: Other: Other: Other: Other: Other: Other: Other.” The general rate of duty will be free. On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or steel products. Additional duties for derivative iron or steel products of 25 percent are reflected in Chapter 99, headings 9903.81.89 and 9903.81.90. Products provided by heading 9903.81.91 will be subject to a duty
of 25 percent upon the value of the steel content. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.81.91, in addition to subheading 8431.49.9095, HTSUS. Derivative iron or steel products processed in another country from steel articles melted and poured in the United States, provided for in heading 9903.81.92, are not subject to the additional ad valorem duties. Please note that derivative steel products admitted to a U.S. foreign trade zone under ?privileged foreign status? before March 12, 2025, and entered for consumption on or after March 12, 2025, may be subject to additional duties under heading 9903.81.93, HTSUS. 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 Paul Huang at [email protected].
Sincerely,
Steven A. Mack Director National Commodity Specialist Division