RE: The tariff classification and country of origin of a tire inflator

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 N364408 September 2, 2026 CLA-2-84:OT:RR:NC:N1:102 CATEGORY: Classification; Origin TARIFF NO.: 8481.80.5090 Vera Zhang Autowin Group Limited Flat/RM 08, 15/F Witty Commercial Building 1A-1L Tung Choi Street Mongkok, Kowloon, Hong Kong China RE: The tariff classification and country of origin of a tire inflator Dear Ms. Zhang: In your letter dated August 20, 2026, you requested a tariff classification and country of origin determination ruling. The product at issue is a tire inflator, model SP00006. This device features an air hose assembly, a digital LCD display for pressure readings, and a valve housed in a pistol-grip body design (main body and trigger) constructed of plastic material. Once the power button is activated, the user can monitor tire pressure and based on the display reading, operate the valve to inflate or deflate the tire as needed. The tire inflator is packaged with batteries from China. In your submission, you suggest classification in heading 8467, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. According to the Explanatory Notes (ENs) to heading 8467, the heading provides for “…tools which incorporate an electric motor, a compressed air motor (or compressed air operated piston), an internal combustion motor, or any other motor…” Based on the submitted information, the digital tire inflator does not meet the terms of the heading, as it does not include a motor. As a result, classification in heading 8467, HTSUS, is precluded. Similar to the water spray valves in New York Ruling Letters N324135, dated March 1, 2022, and N337994, dated March 4, 2024, the tire inflator functions essentially as a hand-operated valve that regulates the inflation and deflation process. Valves and similar appliances are specifically provided for within heading 8481, HTSUS.
The applicable subheading for the tire inflator will be 8481.80.5090, HTSUS, which provides for Taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Other appliances: Hand operated: Of other materials: Other. The general rate of duty will be 3 percent ad valorem. With response to origin, the final assembly of the tire inflator occurs in Malaysia using components primarily from China and a pistol-grip body from Malaysia. The final assembly begins by installing an O-ring onto a valve core from China. In the next step, a spring is installed into the valve seat of a trigger from Malaysia. This step is followed by the installation of a valve core and a seat plug into the valve seat. The process continues by inserting an O-ring, a steel ball and a spring into a valve cap hole. The trigger assembly (a valve cap from Malaysia, the trigger and a pivot pin) is then c onnected to a main body from Malaysia. In the next step, an air inlet fitting and air hose assembly from China are screwed into the main body. Finally, a gauge assembly (produced in Malaysia using components from Malaysia and China) is mounted on the main body and screwed in place. Once finished, the device is tested, inspected and packaged with batteries from China. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (HQ) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed 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). When determining the country of origin of valves, CBP has relied on the origin of the valve body, the essential component of a valve, as the process of assembling a valve is rather simple. Components are typically assembled into a valve body by inserting, pressing, and screwing components to each other. See New York Rulings N339513, dated May 6, 2024, N338713, dated April 3, 2024, N325765, dated May 26, 2022, and N322652, dated December 2, 2021. Therefore, as the processes described above do not result in a substantial transformation, we rely on the origin of the valve body, which consists of the trigger and the main body, to determine the origin of the product. Therefore, as the origin of the valve body is Malaysia, the origin of the tire inflator is Malaysia. 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. 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. 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 Sandra Martinez at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division