The tariff classification of a cam phaser rotor from Brazil
Active· CBP ruling HQ N354769· Issued 2025-11-06
Ruling text
N354769 November 6, 2025 CLA-2-84:OT:RR:NC:N2:201 CATEGORY: Classification TARIFF NO.: 8409.91.5085; 9903.81.91; 9903.01.77; 9903.02.09 Fabio Ravazzi GKN Sinter Metals Ltda. Emancipacao 4500 Hortolândia, Sao Paulo 13186-542 Brazil RE: The tariff classification of a cam phaser rotor from Brazil Dear Mr. Ravazzi: In your letter dated October 8, 2025, you requested a tariff classification ruling. The article under consideration has been identified as a cam phaser rotor, part number F-558189.19-0061. You state the application is for passenger vehicles, specifically the Stellantis HEMI engine. The function of the article is to mechanically modulate the camshaft rotation for optimal valve timing. It integrates/works exclusively with the camshaft. In your request you suggest classification of the cam phaser rotor in subheading 8409.91, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of piston engines or 8483.90, HTSUS, which provides for parts suitable for use solely or principally with transmission shafts (including camshafts), gears, and related mechanical systems. This office agrees it would fall under HTSUS subheading 8409.91, HTSUS, which provides for other parts suitable for use solely or principally with spark-ignition internal combustion piston engines (including rotary engines). The applicable classification subheading for the cam phaser rotor, part number F-558189.19-0061, will be 8409.91.5085, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts suitable for use solely or principally with the engines of heading 8407 or 8408: Other: Other: Other: Other.” The rate of duty will be 2.5% ad valorem. On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter 99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 percent upon the value of the steel content. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.81.91, in addition to subheading 8409.91.5085, HTSUS. Derivative iron or steel products processed in another country from steel articles melted and poured in the United States, provided for in heading 9903.81.92, are not subject to the additional ad valorem duties. Effective August 6, 2025, Executive Order 14323 imposed additional duties on products from Brazil. At this time, products of Brazil provided by heading 9903.01.77, except for products described in headings 9903.01.78 – 9903.01.83, will be subject to an additional ad valorem rate of duty of 40 percent. For products covered by heading 9903.81.91 this additional duty applies to the non-steel content of the merchandise. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e., 9903.01.77, in addition to subheading 8409.91.5085, HTSUS, listed above. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of Brazil will be subject to an additional ad valorem rate of duty of 10 percent. For products covered by heading 9903.81.91, this additional duty applies to the non-steel content of the merchandise. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.09, in addition to subheading 8409.91.5085, HTSUS, listed above. The tariffs and additional 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/. 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 matthew.sullivan@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division
Source: rulings.cbp.gov — ruling N354769, retrieved 2026-10-12T06:05:08Z, republished verbatim. This digest is informational; only CBP issues binding rulings.