The tariff classification of utility refrigerated semi-trailers from Mexico

N354622 October 23, 2025 CLA-2-87:OT:RR:NC:N2:201 CATEGORY: Classification TARIFF NO.: 8716.39.0090; 9903.81.91; 9903.01.27 Patrick Childress Holland & Knight LLP 800 17th ST NW, Suite 1100 Washington, DC 20006 RE: The tariff classification of utility refrigerated semi-trailers from Mexico Dear Mr. Childress: In your letter dated October 3, 2025, you requested a tariff classification ruling of utility refrigerated trailers on behalf of your client, Utility Trailer Manufacturing Company, located in City of Industry, CA. The items under consideration have been identified as the 3000R and 3000R Multi-Temp utility refrigerated semi-trailers, commonly known as “reefer” semi-trailers. These trailers are large, non-self-propelled freight trailers with insulated cargo enclosures and integrated refrigeration units used to transport perishable goods, including food and medicine. You state that the 3000R, which is the base model, is equipped with foam-in-place insulation that provides 360-degree foam to ensure that the entire trailer is fully insulated. You express a standard utility refrigerated trailer measures approximately 53 feet in length, 102 inches in width, and 13 feet 6 inches in overall height. These trailers are a rigid rectangular cargo container mounted on a chassis. The cargo container is fully insulated to maintain cold temperatures, featuring thick insulated walls, roof, and floor. The trailer interior is accessed via rear swing doors that are also insulated and sealed to prevent thermal leakage. The refrigeration unit (typically mounted on the front nose of the trailer) consists of a self-contained diesel engine and compressor system for cooling; this unit operates independently of the tractor and can maintain sub-freezing or chilled temperatures inside the trailer. The second item under consideration has been identified as the 3000R Multi-Temp model. It incorporates all the functions, components, and characteristics of the standard 3000R model and undergoes the same manufacturing processes at the facility in Mexico, as described above. In addition, they feature one or two remote evaporators that allow for multiple temperature-controlled compartments within a single trailer. The vast majority of 3000R Multi-Temp reefers do not include side doors, as they are optional and customizable features. When installed, side doors allow for the unloading of deep-frozen or frozen products from the front or middle sections of the trailer. In your letter, you suggest the refrigerated semi-trailers are classified within subheading 8418.69.0180, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Refrigerators, freezers and other refrigerating or freezing equipment, electric or other; heat pumps, other than the air conditioning machines of heading 8415; parts thereof: Other refrigerating or freezing equipment; heat pumps: Other: Other refrigerating or freezing equipment.” We disagree, as these trailers are fundamentally designed for transporting goods to include temperature-sensitive goods. Section XVII specifically provides for trailers, which are excluded from Section XVI in accordance with legal Note l of Section XVI. The applicable subheading for the 3000R and 3000R Multi-Temp utility refrigerated semi-trailers will be 8716.39.0090, HTSUS, which provides for “Trailers and semi-trailers; other vehicles, not mechanically propelled; and parts thereof: Other trailers and semi-trailers for the transport of goods: Other: Other: Other: Other.” The general duty rate 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 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 8716.39.0090, 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. Products of Mexico as provided by heading 9903.01.01 in Section XXII, Chapter 99, Subchapter III, U.S. Note 2(a), HTSUS, other than products classifiable under headings 9903.01.02, 9903.01.03, 9903.01.04, and 9903.01.05, HTSUS, will be subject to an additional 25 percent ad valorem rate of duty. 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 applicable Chapter 99 heading, i.e. 9903.01.01, in addition to subheading 8716.39.0090, HTSUS, listed above. Articles that are entered free of duty under the terms of general note 11 to the HTSUS (U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set forth in subchapter XXIII of Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be subject to the additional ad valorem duties provided for in heading 9903.01.01. If your product is entered duty free as originating under the USMCA, you must report heading 9903.01.04, HTSUS, in addition to subheading 8716.39.0090, HTSUS. 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 Mexico are not subject to reciprocal tariffs. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.27, in addition to subheading 8716.39.0090, 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 Matthew Sullivan at matthew.sullivan@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division