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9903.91.15: Attestation Exception for Ship-to-Shore Cranes

Published: November 3, 2026  ·  5 min read
9903.91.15: Attestation Exception for Ship-to-Shore Cranes
Photo: Simon R. Minshall / Pexels

Key Points

On this page

  1. What 9903.91.15 is and what it does
  2. Affected products and HTS coverage
  3. The three attestations
  4. Dates and applicability
  5. Interaction with 9903.91.14 and the regular duty line
  6. What importers should do
  7. Key references

9903.91.15 is a Section 301 China Escalation exception heading for ship-to-shore gantry cranes. Importers of those cranes need to know it, because it is the claim heading for cranes that are not tied to China. It adds no duty: the rate is "the duty provided in the applicable subheading," for entries on or after November 10, 2026, as of November 2026.

The links in this article go to the primary documents: the proclamations, Federal Register notices, and official tariff schedule pages themselves. Read the source. For this heading, the controlling text is the heading language in the Harmonized Tariff Schedule and the USTR notice that created it.

What 9903.91.15 is and what it does

9903.91.15 sits beside 9903.91.14, the Section 301 duty heading for ship-to-shore gantry cranes that takes effect November 10, 2026. Where 9903.91.14 is the duty heading, 9903.91.15 is the way out of it for cranes that meet the attestation conditions.

Think of it as a claim heading. Nothing is added to your duty bill by claiming it. You are telling CBP that the cranes qualify for the exception, and you are standing behind that statement as importer.

Affected products and HTS coverage

The heading text describes the covered goods this way: ship-to-shore gantry cranes, configured as a high- or low-profile steel superstructure and designed to unload intermodal containers from vessels with coupling devices for containers, including spreaders or twist-locks. The heading says these are provided for in subheading 8426.19.00.

Three points matter for classification review:

The three attestations

The heading requires the importer to attest to all three of the following. The wording below follows the heading text.

1. Not products of China

The ship-to-shore gantry cranes are not products of China.

2. No Chinese components, assemblies or subassemblies

The cranes are not manufactured, assembled, or made using components, assemblies or subassemblies that are products of China. The heading points to subdivision (l)(ii) of note 31 to the subchapter for the specifics.

3. Not made by a Chinese-owned or controlled entity

The cranes are not manufactured by a company or other entity that is owned or controlled by a Chinese person or legal entity. The heading points to subdivision (l)(v) of note 31 for the specifics.

These are cumulative as written: the heading lists them as (1), (2), and (3) joined by "and." A crane that fails any one of them does not fit the exception on its face. The definitions that give these terms meaning are in note 31, not in this article, so pull the note text before you rely on a supplier's summary.

Dates and applicability

The heading is effective with respect to entries on or after November 10, 2026. As of November 2026, that date is still ahead, so no entry can yet use the heading for its stated window. The facts available to us do not give an end date, so confirm the current status in the HTSUS before each filing.

The facts also do not say anything about refunds, retroactive claims, or how entries before November 10, 2026 are treated. Do not assume any of that. Check with your broker and the USTR notice.

Interaction with 9903.91.14 and the regular duty line

The opening words of the heading, "Notwithstanding heading 9903.91.14," define the relationship. 9903.91.14 is the duty heading being excepted. 9903.91.15 is the exception for attested cranes.

On an entry, a Chapter 99 heading is reported alongside the regular chapter 1 to 97 line. For these cranes, the regular line is 8426.19.00, and its general column rate is what applies under 9903.91.15, since the stated rate is "the duty provided in the applicable subheading." We do not state that rate here because it is not in the facts for this heading. Confirm it in the HTSUS.

The facts do not address how this heading interacts with other tariff programs. For a broader view of how Chapter 99 headings are organized, see our 2026 tariff code overview. For another China Section 301 heading in transportation equipment, see 9903.91.12 on intermodal chassis.

What importers should do

Key references


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About the Author

Franz Brotzen, CustomsGenius CEO & Founder. Franz is a published researcher on U.S. trade policy. He has worked at think tanks in Washington DC and Tokyo, where his academic publications focussed on tariffs and legal compliance. Franz received his JD from Harvard Law School.

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