The tariff classification of coil over shocks from New Zealand

N356461 December 18, 2025 CLA-2-88:OT:RR:NC:N2:206 CATEGORY: Classification; Marking TARIFF NO.: 8807.30.0030 Bryan Norman 3538 Timothy Lane Richmond, TX 77406 RE: The tariff classification of coil over shocks from New Zealand Dear Mr. Norman: In your letter dated November 26, 2025, you requested a tariff classification, marking, and eligibility under the Civil Aircraft Agreement (CAA) ruling. The article under consideration is the KONI Coil Over Shocks used in the landing gear of an experimental/homebuilt personal use aircraft, specifically the Lancair 235 through 360 MK II aircraft. The product consists of an aluminum housing, steel coil spring, buna o-ring and shock oil inside the housing, and chrome piston rod. The item is anodized black and powder coated/painted coil spring. It is imported assembled into one composite good. In our further communication, you stated that the coil over shocks is designed specifically for your personal aircraft and cannot be used for any other purpose. Classification You suggested classification of the KONI Coil Over Shocks in subheading 8803.30.00, Harmonized Tariff Schedule of the United States (HTSUS). However, this subheading no longer exists. The applicable subheading for the KONI Coil Over Shocks will be 8807.30.0030, HTSUS, which provides for “Parts of goods of heading 8801, 8802 or 8806: Other parts of airplanes, helicopters or unmanned aircraft: For use in civil aircraft: Other.” The general rate of duty will be Free. The 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on the Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ. Marking The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article. As provided in section 134.41(b), Customs Regulations (19 CFR 134.41(b)), the country of origin marking is considered conspicuous if the ultimate purchaser in the U.S. is able to find the marking easily and read it without strain. With regard to the permanency of a marking, section 134.41(a), Customs Regulations (19 CFR 134.41(a)), provides that as a general rule marking requirements are best met by marking worked into the article at the time of manufacture. For example, it is suggested that the country of origin on metal articles be die sunk, molded in, or etched. However, section 134.44, Customs Regulations (19 CFR 134.44), generally provides that any marking that is sufficiently permanent so that it will remain on the article until it reaches the ultimate purchaser unless deliberately removed is acceptable. Section 134.32 lists the general exceptions to the marking requirements, one of which is relevant to the case at issue: (f) Articles imported for use by the importer and not intended for sale in their imported or any other form; As long as the district director or the Center director is satisfied that the KONI Coil Over Shocks will be used only in the manner described above, they qualify for the country of origin marking exception set forth in 19 CFR 134.32(f) and, as such, they do not need to be marked to indicate their country of origin. Civil Aircraft Agreement The Agreement on Trade in Civil Aircraft was implemented by Title VI, “Civil Aircraft Agreement” of the Trade Agreements Act of 1979 (Sec. 601, Pub. L. 96-39, 93 Stat. 144, 96th Cong., 1st Sess. 1979), effective January 1, 1980, and became headnote 3 to schedule 6, part 6, Tariff Schedules of the United States (“TSUS”). Headnote 3 to schedule 6, part 6, TSUS, became GN 3(c)(iv) when the Harmonized Tariff Schedule of the United States (“HTSUS”) was enacted, and became GN 6, HTSUS, with minimal changes in 1995. GN 6, HTSUS, was then amended by section 12 of the Miscellaneous Trade and Technical Corrections Act of 1996, Pub. L. 104-295, 110 Stat. 3514 (Oct. 11, 1996). Subsection (a) of GN 6, HTSUS, provides: (a) Whenever a product is entered under a provision for which the rate of duty “Free (C)” appears in the “Special” subcolumn and a claim for such rate of duty is made, the importer-- (i) shall maintain such supporting documentation as the Secretary of the Treasury may require; and (ii) shall be deemed to certify that the imported article is a civil aircraft, or has been imported for use in a civil aircraft and will be so used. In the instant case, the KONI Coil Over Shocks is classified under subheading 8807.30.0030, HTSUS. We note that this subheading is not a CAA eligible provision. Accordingly, the coil over shocks is not eligible for duty-free treatment under the CAA. 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