The tariff classification of a front subframe and control arms from Poland

N359677 March 30, 2026 CLA-2-87:OT:RR:NC:N2:206 CATEGORY: Classification TARIFF NO.: 8708.99.8180; 8708.80.6590 Pawel Cybulski CYBUL Radical Solutions Ul. Gen. Wladyslawa Sikorskiego 5 Lajski 05-119 Poland RE: The tariff classification of a front subframe and control arms from Poland Dear Mr. Cybulski: In your letter dated March 12, 2026, you requested a tariff classification ruling. The articles under consideration are a Tubular Front Subframe (Part Number MX5-XNA-SAN-KIX-001), an Adjustable Camber Control Arms (Part Number MX5-NAB-WAH-XPG-001), and an Adjustable Front Control Arms (Part Number JEP-ZXJ-WAH-PTG-001) used in passenger vehicles. The Tubular Front Subframe is an aftermarket good designed to replace the original stamped steel front subframe in a Mazda MX-5 NA (1989-1997). The subframe serves as the primary load-bearing structure connecting lower and upper control arms, engine mounts, and steering components. Additional mounting points positioned 18 mm higher provide roll center correction for lowered vehicles, improving suspension geometry and reducing understeer. The triangulated chromoly tubular construction increases torsional stiffness while reducing overall weight compared to the OEM component. The method of installation includes the subject merchandise being bolted directly to the factory chassis mounting points with included mounting hardware. The total weight of the carbon steel subframe is approximately 33 lbs. The Adjustable Camber Control Arms is an aftermarket set designed for installation in a Mazda MX-5 NA (1989-1997) and NB (1998-2005). The primary function of the product is to connect the wheel hub assembly to the chassis while allowing adjustment of the camber angle. The product improves suspension geometry tuning capability and increases structural rigidity in comparison to OEM steel control arms. The Adjustable Camber Control Arms form a part of the suspension linkage system. The product pivots at the chassis mounting points using polyurethane bushings and connects to the hub assembly via a pivot mechanism. The adjustable geometry allows precise camber angle setting over a wide adjustment range. Suspension response and handling stability is improved by the structural integrity of the 4130 chromoly tubular construction. The method of installation includes bolting the product to the factory suspension mounting points using supplied hardware and OEM pivot location. The material composition of the main structure is 4130 chromium-molybdenum steel tubing and sheet metal, the pivot housing is constructed of 7075-T6 aluminum, and the bushings are composed of polyurethane. The total weight of the Adjustable Camber Control Arms is approximately 6 lbs. At the time of U.S. importation, the Adjustable Camber Control Arms will include two adjustable control arms, two pivots with nuts, two aluminum pivot housings, polyurethane bushings, steel washers, pivots, and steel sleeves. The Adjustable Front Control Arms-Off-Road Application is an aftermarket suspension control arm designed for off-road motor vehicle use in a Jeep ZJ, TJ, and XJ. The primary function of the product is to connect the axle assembly to the vehicle chassis and allow adjustment of the pinion and caster angles after suspension lift modifications. The component provides a recentering of the axle within the wheel arch after suspension height changes. The length of the subject merchandise allows for an approximate 16" to 19" adjustment allowing for correction of the drivetrain angle and steering geometry after suspension lift. The control arm maintains proper axle alignment and reduces driveline vibration caused by incorrect pinion angles. The offset front sleeve design prevents interference with the chassis mounts during high suspension lift applications. The total weight of the Adjustable Front Control Arms is approximately 13 lbs. The applicable subheading for the Tubular Front Subframe, Part Number MX5-XNA-SAN-KIX-001 will be 8708.99.8180, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and accessories of the motor vehicles of heading 8701 to 8705: Other parts and accessories: Other: Other: Other: Other: Other: Other.” The general rate of duty will be 2.5 percent, ad valorem. The applicable subheading for the Adjustable Camber Control Arms, Part Number MX5-NAB-WAH-XPG-001 and the Adjustable Front Control Arms-Off-Road Application, Part Number JEP-ZXJ-WAH-PTG-001 will be 8708.80.6590, HTSUS, which provides for “Parts and accessories of the motor vehicles of heading 8701 to 8705: Other parts and accessories: Suspension systems and parts thereof (including shock absorbers): Parts: Other: Other: Other.” The general rate of duty will be 2.5 percent ad valorem. 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 Liana Alvarez at liana.alvarez@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division