CBP Ruling N305741 — The tariff classification of a body seal from Korea

Tariff classification

Headings: 4016

Product description

The subject product is called a body seal, identified by Item Code 808302417R. You note that it is a rubber strip with plastic clips inserted at regular intervals and a plastic resin on the end. The strip is composed of cellular ethylene propylene diene monomer (EDPM) rubber. You indicate that the seal will be mounted along the door of the car to absorb the impact when opening and closing and prevent foreign matter such as rainwater from entering from the outside. You suggest classification of the subject product in subheading 4016.93, Harmonized Tariff Schedule of the United States (HTSUS) which provides for other articles of vulcanized rubber other than hard rubber: Other: Gaskets, washers and other seals and cite NY A81113, dated April 3, 1996, in support of your position. In NY Ruling, N293391, which discussed a similar issue and referenced A81113, it is indicated that: “The rubber articles classified in that ruling were comprised entirely of compact rubber. Historically, similar items, when comprised of both compact and cellular rubbers, have been classified under a cellular rubber provision.” This product only contains cellular rubber.

CBP rationale

The applicable subheading for the body seal will be 4016.10.0000, HTSUS, which provides for Other articles of vulcanized rubber other than hard rubber: Of cellular rubber.

Full text

N305741 August 26, 2019 CLA-2-40:OT:RR:NC:N1:137 CATEGORY: Classification TARIFF NO.: 4016.10.0000 Bo Ram Kim Yooil Rubber Co., Ltd. 152 Jangansandan-ro Jangan-eup, Gijang-gun Busan, ASI|KR|KS012|Pusan, South Korea RE: The tariff classification of a body seal from Korea Dear Mr. Kim: In your letter dated August 12, 2019, you requested a tariff classification ruling. The subject product is called a body seal, identified by Item Code 808302417R. You note that it is a rubber strip with plastic clips inserted at regular intervals and a plastic resin on the end. The strip is composed of cellular ethylene propylene diene monomer (EDPM) rubber. You indicate that the seal will be mounted along the door of the car to absorb the impact when opening and closing and prevent foreign matter such as rainwater from entering from the outside. You suggest classification of the subject product in subheading 4016.93, Harmonized Tariff Schedule of the United States (HTSUS) which provides for other articles of vulcanized rubber other than hard rubber: Other: Gaskets, washers and other seals and cite NY A81113, dated April 3, 1996, in support of your position. In NY Ruling, N293391, which discussed a similar issue and referenced A81113, it is indicated that: “The rubber articles classified in that ruling were comprised entirely of compact rubber. Historically, similar items, when comprised of both compact and cellular rubbers, have been classified under a cellular rubber provision.” This product only contains cellular rubber. The applicable subheading for the body seal will be 4016.10.0000, HTSUS, which provides for Other articles of vulcanized rubber other than hard rubber: Of cellular rubber. The general rate of duty will be free. 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 on the World Wide Web at https://hts.usitc.gov/current. This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Christina Allen at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division

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