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

N355320 November 20, 2025 CLA-2-87:OT: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 guard Dear Mr. Kwon: In your letter dated October 27, 2025, you requested a tariff classification and country of origin determination ruling on a car door guard, which you filed on behalf of your client, Guardian Co., Ltd. The article under consideration is the Car Door Guard, Model: Neo Guard. It functions as a protective device that attaches across the vehicle door to prevent external door damage, such as accidental impacts, dents, scratches, and door dings, which can occur when a vehicle’s door makes forceful contact with an adjacent car, wall, or object, primarily in tight parking spaces or close proximity to other vehicles. The article consists of three primary components: a thermoplastic elastomer (TPE) main body/rubber bar, acrylonitrile butadiene styrene (ABS) armor cap (plastic cover for the TPE rubber bar), and 3M adhesive tape. The armor cap is fitted on top of the rubber bar to provide extra protection and the 3M adhesive tape is added for the user to attach the rubber bars securely to the vehicle’s door. The manufacturing process takes place in South Korea starting with TPE pellets of South Korean origin that are blended, dried and molded to form the main body or rubber bar. Then ABS pellets from South Korean origin are colored, blended, dried and molded to create the armor caps. Next, strips of 3M tape from the United States are bonded to the rubber bars using the 3M primer from South Korea and then the rubber bars are fitted with the armor caps. The finished door protector will be packaged in a retail box together with the alcohol swab from South Korea, masking tape from Japan and labels from China ready for shipment to the United States. 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 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 Guard, Model: Neo Guard, 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). Regarding the origin of the car door guard, the rubber bars and armor caps are both produced in South Korea, using the South Korean origin materials (TPE and ABS pellets) to produce the finished door protector. The TPE and ABS pellets of South Korean origin are substantially transformed into an identifiable car door guards in South Korea when they undergo the molding and forming processes. Based on the information provided, it is the opinion of this office that the country of origin for the Car Door Guard, Model: Neo Guard 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) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division