The tariff classification and country of origin of a harmonic planetary reducer

N361005May 20, 2026CLA-2-84:OT:RR:NC:N1:102 CATEGORY: Classification; Origin TARIFF NO.: 8483.40.5010 Marcus ZinnHanwha Qcells Georgia, Inc.100 Qcells Parkway, Suite 250White, GA 30184RE: The tariff classification and country of origin of a harmonic planetary reducerDear Mr. Zinn:In your letter dated April 24, 2026 , you requested a tariff classification and country of origin ruling to applycurrent trade remedies and for marking purposes.The product at issue is a Harmonic Planetary Reducer, model number HPG-20A-21-F0GCK. The planetary reducer is configured as a planetary gearbox that reduces speed in a fixed ratio (21:1). The gearrotational boxtransmit power to jointconsists of an aluminum housing that incorporates six gears and is designed to actuators used in various industries such as robotics, semiconductor manufacturing and machine tools. in The applicable subheading for the planetary reducer will be 8483.40.5010, Harmonized Tariff Schedule ofthe United States (HTSUS), which provides for Transmission shafts (including camshafts and crankshafts)and cranks; bearing housings, housed bearings and plain shaft bearings; gears and gearing; ball or rollerscrews; gear boxes and other speed changers, including torque converters; flywheels and pulleys, includingpulley blocks; clutches and shaft couplings (including universal joints); parts thereof: Gears and gearing,other than toothed wheels, chain sprockets and other transmission elements entered separately; ball or rollerscrews; gear boxes and other speed changers, including torque converters: Gear boxes and other speedchangers: Fixed ratio speed changers, multiple and variable ratio speed changers each ratio of which isselected by manual manipulation: Other: Fixed ratio speed changers. The general rate of duty will be 2.5percent ad valorem.With respect to origin, the final assembly occurs in South Korea using components sourced from Japan andSouth Korea. The process begins by inserting input coupling into housing from South Koreaana.gears from Japan are pressed into the housing and South Korea are interfacedAfterwards, six bearings from fitted.the components are as needed Lastly, bolted in place, and the finished planetary reducer is labeled andpackaged ready for shipment. When determining the country of origin for purposes of applying current trade remedies under Section 301and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters RulingLetter H301619, dated November 6, 2018. The test for determining whether a substantial transformation willoccur is whether an article emerges from a process with a new name, character, or use different from thatpossessed 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).Here, the final assembly of the planetary reducer involves the insertion and press-fitting of components into ahousing, followed by a bolting process. These processes are not particularly complex and do not substantiallytransform the non-South Korean components, such as the six gears. While the South Korean housing enclosesthe components, the gears are directly responsible for the transmission of power and constitute a significantportion of the planetary reducer’s overall bulk and value. Consequently, based on the bulk, value andsignificant function of the gears, which are of Japanese origin, the country of origin of the planetary reduceris Japan.The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.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 providedat https://hts.usitc.gov/.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties 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 eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Sandra Martinez at sandra.martinez@cbp.dhs.gov. Sincerely, (for)James P. ForkanDirectorNational Commodity Specialist Division