The tariff classification and country of origin of a wheel dolly

N356009 December 11, 2025 CLA-2-87:OT:RR:NC:N2:201 CATEGORY: Classification; Origin TARIFF NO.: 8716.80.5090; 9903.81.91; 9903.01.26 Ted Brockman Talo Holdings Ltd. DBA Wheel Boost 50534 Range Road 224 Leduc County T0B 3M1 Canada RE: The tariff classification and country of origin of a wheel dolly Dear Mr. Brockman: In your letter dated November 13, 2025, you requested a tariff classification and country of origin determination ruling. The item under consideration is a wheel dolly referred to as the “Wheel Boost,” which allows a single person to easily change/swap the tires of a vehicle. A video provided with your submission shows the “U” shaped dolly being fitted to a mounted tire. The Wheel Boost is tightened, driven by an electric drill or power ratchet, which lifts and supports the tire allowing it to be easily rolled off the wheel hub. You have indicated that you currently have four (4) models of various sizes for customers to choose from, depending on the size of their tires. 1. WB-18-30-SS - for compact cars to Mid-Size SUV's and Pick Ups 2. WB-22-38-SS - For mid-size SUV's to HD Pick Ups 3. WB-26-42-SS - For oversize, offroad and rock climber tires. 4. WB-32-48-SS - For monster truck tires up to 48" diameter In the supplied video, you show raw materials, sheets of stainless steel, that you indicate are sourced from Taiwan and melted in Indonesia. These sheets are cut, bent, and shaped by machines in Canada forming the “U”-shaped body of the Wheel Boost. The casters are sourced from the United States and China, and the gravity rollers are manufactured domestically in Canada. The Wheel Boost is hand assembled and hand packaged in the retail packaging by your company in Canada. The applicable subheading for the Wheel Boost will be 8716.80.5090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Trailers and semi-trailers; other vehicles, not mechanically propelled; and parts thereof: Other vehicles: Other: Other: Other.” The general rate of duty will be 3.2% 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). Based on the video provided, it is clear to this office that the manufacturing processes that take place in Canada to the foreign sourced stainless-steel sheets is substantial and meaningful, and that the raw materials come out with a new name and purpose after processing. It is the opinion of this office that the Wheel Boost is a Product of Canada. 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 8716.80.5090, 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 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. 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. 9903.01.10, in addition to subheading 8716.80.5090, 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 8716.80.5090, 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, 9903.01.26, in addition to subheading 8716.80.5090, 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) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division