The tariff classification of pulleys from China

N354127 October 7, 2025 CLA-2-84:OT:RR:NC:N1:102 CATEGORY: Classification TARIFF NO.: 8483.50.9040; 9903.01.24; 9903.81.91; 9903.01.25; 9903.88.01 Takayuki Hirano Shima American Corporation 500 Park Blvd., Suite 760 Itasca, IL 60143 RE: The tariff classification of pulleys from China Dear Mr. Hirano: In your letter dated September 23, 2025, you requested a tariff classification ruling. Descriptive information was provided with your submission. The items at issue are steel pulleys, item numbers PN161-1031, PN161-1043 and PN161-1078. The grooved pulleys are configured as wheels that transmit power using a belt system. The pulleys drive the rotation of cutting or thrashing blades installed in commercial lawn mowers, which can be used for large acreage mowing and pasture maintenance. The applicable subheading for the steel pulleys will be 8483.50.9040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Transmission shafts (including camshafts and crankshafts) and cranks; bearing housings, housed bearings and plain shaft bearings; gears and gearing; ball or roller screws; gear boxes and other speed changers, including torque converters; flywheels and pulleys, including pulley blocks; clutches and shaft couplings (including universal joints); parts thereof: Flywheels and pulleys, including pulley blocks: Other: Other: Grooved pulleys. The general rate of duty will be 2.8 percent ad valorem. 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 8483.50.9040, HTSUS, listed above. 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 50 percent are reflected in Chapter 99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 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 8483.50.9040, 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. 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. For products covered by heading 9903.81.91 this additional duty applies to the non-steel content of the merchandise. 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 8483.50.9040, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8483.50.9040, 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., 9903.88.01, in addition to subheading 8483.50.9040, HTSUS, listed above. Additionally, you requested that the pulleys be considered for duty-free treatment under subheading 9817.00.60, HTSUS. Section 177.7 of the Customs Regulations (19 C.F.R. §177.7) provides that rulings will not be issued in certain circumstances. Specifically, Part 177.7(b) reads, in pertinent part: No ruling letter will be issued with respect to any issue which is pending before the United States Court of International Trade, the United States Court of Appeals for the Federal Circuit or any court of appeal. As such, CBP will not issue a ruling regarding the eligibility of the pulleys under subheading 9817.00.60, HTSUS, at this time. The classification determination may be impacted by court cases currently pending in the Court of International Trade. See Great States Corporation DBA American Lawn Mower Co. v. United States, Court No. 24-00216; Melnor Inc. v. United States, Court No. 25-00052; and Hydro Gear v. United States, Court No. 23-00044. 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 Sandra Martinez at sandra.martinez@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division