The tariff classification of fuel injection rails from Japan

N354522 October 24, 2025 CLA-2-87:OT:RR:NC:N2:206 CATEGORY: Classification TARIFF NO.: 8708.99.8180; 9903.81.91; 9903.01.33 Travis Scoby Sanoh America, Inc. 1849 Industrial Drive Findlay, OH 45840 RE: The tariff classification of fuel injection rails from Japan Dear Mr. Scoby: In your letter dated October 2, 2025, you requested a tariff classification ruling. The merchandise under consideration is described as fuel injection rails (FIR), which are identified by part numbers 17522AB04A-JPN Rev N, 17522AB07A-JPN Rev N, 17522AB07B-JPN Rev N, and 17523AB09A-JPN Rev N. The components are used in motor vehicles such as small SUVs and sedans. The FIRs are designed to supply pressurized fuel evenly to fuel injectors in automobile engines. The parts are connected directly to the powertrain, specifically on the right or left side of the engine. The components are critical in maintaining adequate fuel distribution to the engine by holding the pressurized fuel and allowing the fuel injectors to rapidly release an exact amount of fuel in a precise manner. The applicable subheading for the fuel injection rails, part numbers 17522AB04A-JPN Rev N, 17522AB07A-JPN Rev N, 17522AB07B-JPN Rev N, and 17523AB09A-JPN Rev N will be 8708.99.8180, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Other: Other: Other.“ The rate of duty will be 2.5 percent ad valorem. 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 8708.99.8180, 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 Japan with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15 percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General duty rate. 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 8708.99.8180, 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