The tariff classification of fixed gooseneck trailers from Poland

N359154 March 10, 2026 CLA-2-:OT:RR:NC:N2:201 CATEGORY: Classification TARIFF NO.: 8716.39.0090 Thomas Gilchrist On-Crane Solutions LLC 26 Ringfield Road Chadds Ford, PA 19317 RE: The tariff classification of fixed gooseneck trailers from Poland Dear Mr. Gilchrist: In your letter dated February 24, 2026, you requested a tariff classification ruling on behalf of your client, NT Industry (DBA Novatech APS), located in Aalborg, Denmark. The submission concerns fixed gooseneck industrial roll trailers identified as the RT-Series, including models : RT60 RT80 RT100, and RT120 You state that variations among RT-Series models relate solely to payload capacity and dimensional scaling and do not alter construction, operational characteristics, or principal use. These trailers are designed exclusively for transportation of ISO containers and industrial cargo within marine terminals, ports, steel facilities, and other controlled industrial environments when towed by external tractor units. You state that the RT-Series roll trailers function solely as passive cargo transport platforms. All cargo handling operations are performed exclusively by external equipment. The trailers: Do not lift cargo, Do not load or unload cargo Do not elevate cargo Do not stack or position cargo Do not secure cargo through powered mechanisms Perform no industrial processing function You state that each trailer incorporates the following common features: Fixed gooseneck assembly 2” or 3.5” kingpin towing connection Skeletal I-beam structural chassis (ST355 steel) Steel cargo deck platform ISO container positioning capability D-ring lashing systems Multi-axle running gear Solid rubber industrial tires RT60 RT80 RT100 Size (LxWxH) 14.500 × 2.500 × 1.250 14.500 × 2.500 × 1.250 14.500 × 2.500 × 1.250 Loading Deck Height 800 mm 800 mm 800 mm Capacity 60 Ton 80 Ton 100 Ton Wheel Size 22×12×16” 22×14×16” 22×16×16” In your request you suggest classification of the RT-Series of roll trailers in 8716.39.0090, Harmonized Tariff Schedule of the United States (HTSUS) which provides for semi-trailers. We agree. The applicable subheading for the RT-Series (RT60, RT80, RT100, and RT120) fixed gooseneck 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.” 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 the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division