The tariff classification of incomplete trailers from Canada

N361982
June 15, 2026
CLA-2-87:OT:RR:NC:N2:201
CATEGORY: Classification
TARIFF NO.: 8716.40.0000
Mr. Nick Zosky Dentons Cohen and Grigsby 625 Liberty Ave Pittsburgh, PA 15222 RE: The tariff classification of incomplete trailers from Canada Dear Mr. Zosky: In your letter dated June 2, 2026, you requested a tariff classification ruling, filed on behalf of Kinetic Custom Trailers. The item under consideration has been identified as two (2) unfinished trailers. The first item has been identified as the Kinetic High Capacity “CTU” Trailer. The Kinetic trailer is a purpose-built trailer chassis that will be fitted with highly specialized equipment to provide oil well intervention and maintenance services at the oil well site. You state that one example of this application would be a coil tubing trailer that is used for oil and gas well development. This type of trailer is used at the oil and gas well operation site to hold more than 30,000 feet of continuous steel tubing that is deployed into wells for various purposes, predominantly for oil and gas field operations. The Kinetic is purpose-built and, upon importation, is not in a “ready to use” condition for the customer’s intended field-service application until the customer-specified equipment is permanently installed. The second item has been identified as the Kinetic Custom Equipment-Mounting “Step deck” Chassis. The step deck chassis is a bare painted chassis that includes pre-drilled mounting holes, custom designed cross-members or mounts and mounting brackets that are designed specifically to accept a customer’s equipment. Compared to the Kinetic High Capacity CTU trailer described above, this is a less complex equipment-mounting trailer. A common usage of this type of trailer is that it is outfitted with a natural gas combustion engine and generator to produce power or to directly drive a pump. This type of trailer would typically operate in concert with many others of the same units, sometimes upwards of 15 units on a well site or well location where it is used off highway in operation. Trailers of this type would operate on sites for days or weeks at a time, if not longer, until they are redeployed to another site.

A review of the information provided shows that there are no general transportation platforms, van type enclosures, refrigeration equipment, ISO container twist-locks, container pins, standardized container supports, or intermodal securement features installed on the trailers at time of manufacture or import, nor are they equipped to transport ocean or intermodal containers used in interstate commerce to transport merchandise across the United States. This Kinetic trailer is approximately 14.5 ft wide and 72 ft long and, when connected with its ancillary jeep booster and tractor, will have a gross vehicle weight of up to 400,000 lb. In your request you suggest classification of the Kinetic trailers in 8716.40, Harmonized Tariff Schedule of the United States (HTSUS), which provides for, “Trailers and semi-trailers; other vehicles, not mechanically propelled; and parts thereof: Other trailers and semi-trailers.” We agree. The applicable subheading for the Kinetic High Capacity CTU and Equipment mounting Step Deck trailers will be 8716.40.0000, HTSUS, which provides for “Trailers and semi-trailers; other vehicles, not mechanically propelled; and parts thereof: Other trailers and semi-trailers.” 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 [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division