The tariff classification of a vehicle restraint system from Canada

N355310 November 7, 2025 CLA-2-84:OT:RR:NC:N1:104 CATEGORY: Classification TARIFF NO.: 8479.89.9599; 9903.01.26 Anabela Olveira Blue Giant Equipment Corp. 410 Admiral Blvd. Mississauga, ON L5T2N6 Canada RE: The tariff classification of a vehicle restraint system from Canada Dear Ms. Oliveira: In your letter dated October 27, 2025, you requested a tariff classification ruling. The product in question is the StrongArm HVR303 electrically powered vehicle restraint system. This wall-mounted device is made of steel and used to safely secure trailers at commercial loading docks, preventing horizontal and vertical trailer movement during loading/unloading operations. It includes an electro-mechanical rotating hook, submersible motor, lip guide and ICC bar guide for proper trailer alignment, and an electronic touch control panel. In operation, a trailer is backed into a loading bay where the StrongArm device’s hook secures the trailer’s ICC bar (i.e., rear impact or underride guides). In your submission, you suggest that the StrongArm HVR303 is classifiable under subheading 8425.39, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Pulley tackle and hoists other than skip hoists; winches and capstans; jacks: Winches; capstans: Other. We disagree as the device is not a winch or capstan. As such, heading 8425 is inapplicable. The applicable subheading for the StrongArm HVR303 vehicle restraint system will be 8479.89.9599, HTSUS, which provides for Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other: Other: Other. The general rate of duty will be 2.5 percent ad valorem. Products of Canada as provided by heading 9903.01.10 in Section XXII, Chapter 99, Subchapter III, U.S. Note 2(j), HTSUS, other than products classifiable under headings 9903.01.11, 9903.01.12, 9903.01.13, 9903.01.14, and 9903.01.15, HTSUS, will be subject to an additional 35 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.10, in addition to subheading 8479.89.9599, 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 9903.01.10. If your product is entered duty free as originating under the USMCA, you must report heading 9903.01.14, HTSUS, in addition to subheading 8479.89.9599, 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 Canada 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. 9903.01.26, in addition to subheading 8479.89.9599, 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 Arthur Purcell at arthur.purcell@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division