The Product
- A dynamic damper assembly of steel and rubber, permanently affixed to the metal frames of motor vehicle seats.
- Two metal plates fixed between four rubber bushings, about 5.07 inches long, 4.02 inches wide and 1.32 inches high.
- It absorbs vibrations and shocks in the seat, most often in the upper backrest to reduce headrest shaking, or under the seat.
- It has none of the seat's upholstery, cushions, base, legs or armrests.
CBP's Ruling
| Item | HTS code | CBP's description of the line |
|---|---|---|
| Dynamic damper assembly | HTS 9401.99.1085 | Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Parts: Other: Of seats of a kind used for motor vehicles: Other |
Explanation
CBP placed the damper under heading 9401 as a part of a seat. The letter cites the Explanatory Notes to Chapter 94, which cover parts identifiable by shape or other features as designed solely or principally for goods of headings 9401 to 9403 and 9405. Chapter 94 note 2, the floor-standing rule for furniture, does not apply to parts.
CBP found the damper identifiable by its shape and features as designed for motor vehicle seats, since it joins the seat frame and contributes to the seat's structure, support and function. That fits the Explanatory Notes to heading 9401, which cover identifiable parts of seats.
The damper is metal and rubber. CBP found the metal plates, which counteract and minimize seat vibration, give it its essential character.
Headings CBP ruled out
- Heading 8708 (parts and accessories of motor vehicles): The damper is a component of the seat, and under Mitsubishi Electronics America v. United States a subpart of a part is more specifically provided for as a part of that part than as a part of the whole.
Does this apply to your product?
It likely does if you can answer yes to each of these:
- Is it a part designed solely or principally for a motor vehicle seat?
- Does it attach permanently to the seat frame to absorb shocks and vibration?
- Is it built from metal plates and rubber bushings?
- Does it come without upholstery, cushions, a seat base, legs or armrests?
A no to any of them can mean a different code. A licensed broker can classify your product.
The code today
| HTS code | In today's schedule | Where it sits | Today's duty |
|---|---|---|---|
| 9401.99.1085 | ✓ Still in the schedule | Heading 9401 › Of seats of a kind used for motor vehicles | Today's duty from Japan |
Checked against today's tariff schedule. The duty calculator opens with the code and country filled in.
Related rulings
N348721, N352533, N350961 and N355891 also classify automobile or other seat components on the same 9401.99.1085 line. N355273, N339562, N361875 and N338389 classify seat components on other parts lines of heading 9401.
- N348721May 29, 2025The tariff classification and country of origin of a seat component9401.99.1085
- N339562May 2, 2024Seat component from Cambodia9401.99.9021
- N361875June 1, 2026Seat component from Vietnam9401.99.9085
- N355273November 18, 2025Seat component from South Korea9401.99.1020
- N352533August 20, 2025Automobile seat component from South Korea9401.99.1085
- N350961July 28, 2025Automobile seat component from South Korea9401.99.1085
- N355891November 20, 2025Automobile seat component from South Korea9401.99.1085
- N338389March 19, 2024Seat components from China9401.99.3580
Borderless, a licensed U.S. customs brokerage, summarized CBP ruling N342703 in plain English and checked its codes against the letter and today's tariff schedule. A ruling applies only to goods that match its facts; our terms explain the rest. Terms