The tariff classification and country of origin of a car door edge guard

N354494 October 31, 2025 CLA-2-87OT:RR:NC:N2:206 CATEGORY: Classification; Origin TARIFF NO.: 8708.29.5160; 9903.94.05; 9903.01.33 Jiwon Kwon CUSAN Customs Service Incorporation #309, 35, Magokjungang 2-ro, Gangseo-gu Seoul 07806 South Korea RE: The tariff classification and country of origin of a car door edge guard Dear Mr. Kwon: In your letter dated October 2, 2025, you requested a tariff classification and country of origin determination ruling on a car door edge guard, which you filed on behalf of Guardian Co., Ltd. The article under consideration is the Car Door Edge Guard, Model GP-mini, which functions as a protective device that attaches to the vehicle door edges to prevent contact impacts and potential damage during door operation. The article consists of two primary components: a TPU (thermoplastic polyurethane) main body and 3M adhesive tape. You state that the fundamental protective function of the GP-mini is performed exclusively by the TPU main body component, which absorbs and disperses impact forces when contact occurs between the vehicle door edge and adjacent surfaces. The 3M tape serves solely as an attachment mechanism, enabling the TPU main body to adhere securely to the vehicle door surface. According to the bill of materials supplied with your request, the TPU pellets are sourced from China and imported to South Korea for further processing. In South Korea, the pellets undergo drying and blending. The material is then fed into the injection molding machine, where the GP-mini body is formed as a single integrated structure. Further, an acrylonitrile butadiene styrene (ABS) resin from South Korea is injection molded into the shape of the “G” logo using a precision mold. After the multi-stage electroplating process, the logos are inserted into the pre-formed TPU body. The product then undergoes gates and burrs removal and a comprehensive inspection. Finally, the 3M acrylic foam double-sided tape from the United States is applied to the TPU product and the final product is packed in blister packs in South Korea ready for shipment. In your submission, you suggest that this product should be classified under subheading 3926.30.5000, Harmonized Tariff Schedule of the United States (HTSUS), as an other plastic fitting for coachwork. We disagree. Classification under the HTSUS is made in accordance with the General Rules of Interpretation (GRI’s). GRI 1 provides that the classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative Section or Chapter Notes. Section Note 2(b) to Section XVII excludes “parts of general use” as defined by Section XV, and similar articles of plastics, while Chapter Note 2(t) to Chapter 39 excludes parts of Section XVII. Therefore, if the car door edge guard does not meet the terms of “parts of general use,” it will not be classified in Chapter 39. We refer to the decision provided in Jing Mei Auto (USA) v. United States, 682 F. Supp. 3d 1354, 1374 (Ct. Int’l Trade 2023) in considering whether this article is a fitting within the terms of “parts of general use.” We hold the opinion that it would not meet the definition of a fitting, because it has a utilitarian function of protecting the vehicle door and is not used to join, adjust, or adapt other parts, nor it is solely for aesthetics, as set forth by the court. Therefore, the article is not a fitting; thus, it does not meet the terms of “parts of general use.” As a result, it is not excluded by any legal notes of Section XVII of the HTSUS. The applicable subheading for the Car Door Edge Guard, Model GP-mini, will be 8708.29.5160, HTSUS, which provides for “Parts and accessories of the motor vehicles of heading 8701 to 8705: Other parts and accessories of bodies (including cabs): Other: Other: Other.” The general rate of duty will be 2.5 percent ad valorem. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). In the present case, the TPU pellets from China are substantially transformed into an identifiable car door edge guard in South Korea, when they undergo the molding and forming processes. This decision is supported by HQ 555772, dated January 14, 1991, where the molding of plastic into a specific shape is considered a substantial transformation. Similarly, other components from South Korea and the United States lose their individual identities and become parts of the guard in South Korea. As a result, it is the opinion of this office that the country of origin of the Car Door Edge Guard, Model GP-mini, will be South Korea. Effective May 3, 2025, Presidential proclamation 10908 imposed additional tariffs on certain automobile parts. Additional duties on automobile parts of 25 percent are reflected in Chapter 99, heading 9903.94.05, as provided in subdivision (g) of U.S. note 33 to this subchapter. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.94.05, in addition to subheading 8708.29.5160, 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 South Korea will be subject to an additional ad valorem rate of duty of 15 percent. Your product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.33, in addition to subheading 8708.29.5160, HTSUS, listed above. 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 Liana Alvarez at liana.alvarez@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division