RE: The tariff classification of a seat belt spring assembly from Mexico

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365487 October 14, 2026 CLA-2-73:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7320.90.5060 Angela Herrera Kuehne + Nagel Inc. 555 South Renton Village Plaza, Suite 700 Renton, WA 98057 RE: The tariff classification of a seat belt spring assembly from Mexico Dear Ms. Herrera: In your letter dated September 28, 2026, you requested a tariff classification ruling on behalf of your client, Tram Inc. Informational material was submitted with your request. The merchandise under consideration is a seat belt spring assembly, Part # 7P0702-7053. This assembly is a part for a seat belt retractor used in automotive vehicles to maintain tension in seat belt webbing when worn or retracted when not in use. It consists of a plastic housing, a plastic tension spool, and a spiral steel flat spring. The housing is circular in shape and is composed of two pieces, a container and a cover. The container is where the spring and the spool are installed. Before the cover is applied, the spring is attached to the spool located in the center of the assembly and arranged in such a way that the spring will undergo tension as the spool revolves. The cover is then attached to the container which leaves the spool accessible and free to turn. Once the assembly is coupled with the retractor, the spool can transfer or release the tension in the spring as needed for the seat belt retractor as a whole. In your submission, you suggested the seat belt spring assembly is classifiable under subheading 8708.29.5190, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts and accessories of motor vehicle bodies. We disagree. Classification of merchandise under the HTSUS is governed by the General Rules of Interpretation (GRIs) taken in order. GRI 1 provides that “classification shall be determined according to the terms of the headings and any relative section or chapter notes.” Section XVII, Note 2(b), which includes Chapter 87, excludes “parts of general use as defined in Note 2 to Section XV, of base metal or similar goods of plastics (Chapter 39).” Section XV, Note 2(b) includes springs and leaves for springs, of base metal, as “parts of general use,” and since the article under consideration includes a spring, classification of the seat belt spring assembly in Section XVII is precluded. There is no heading that specifically identifies a seat belt spring assembly, the information does not indicate the item is unassembled on importation, and the item is constructed of two materials, plastic and steel. This would make the item classifiable as a composite good under GRI 3(b) which provides “that mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale shall be classified as if they consisted of the material or component which gives them their essential character.” The Explanatory Notes (ENs) to GRI 3(b) (VIII) state that “The factor which determines essential character will vary as between different kinds of goods. It may, for example, be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the goods.” In this case, based on the information provided, the steel spring imparts the essential character, because the assembly cannot function or be used without it. Therefore, the seat belt spring assembly is appropriately classified in heading 7320, HTSUS, which provides for “Springs and leaves for springs, of iron or steel.” The applicable subheading for the seat belt retractor will be 7320.90.5060, HTSUS, which provides for “Springs and leaves for springs, of iron or steel: Other: Other: Other.” The general rate of duty will be 2.9 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 Matthew Gay at matthew.gay@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division