CLA-2-84:OT:RR:NC:N1:103

Lucy Holt
Beckhoff Automation, LLC
13130 Dakota Ave. Savage, MN 55378

RE:  The tariff classification of a linear transport system and its components from Germany

Dear Ms. Holt:

In your letter dated August 7, 2023, you requested a tariff classification ruling.

The first item under consideration is identified as the XTS Linear Transport System, item number 81571, which consists of motor modules, guide rails, movers, and a base plate. Designed for product transport, the components are assembled to form a modular track fitted with magnetically driven movers that move along a travel path of motor modules. The movers in the system are passive and capable of moving individually along the track to transport objects to different processing stations. The XTS Linear Transport System can be configured with an open or closed travel path, is scalable, and can be mounted horizontally, vertically, or at an angle.

The second item under consideration is referred to as a motor module, part number AT2002-0250-0002. The module measures 250 millimeters in length and is composed of an electric motor section, a feedback system to detect position, and a 180-degree rotating connector, which is used for data communication and to supply power to the module. The electric motor section is configured with a series of coils designed to create an electromagnetic field. Multiple motor modules are connected together to form a continuous track, which is then equipped with movers. When the modules are energized in a sequential pattern, the movers travel in a controlled manner along the track.

The third item under consideration, item 233046, primarily consists of a lubrication pump with a reservoir and a motor. Once activated by a control system, the lubrication pump disburses minute amounts of lubricant onto a rail in a pre-determined frequency. The volume of lubricant delivered by the pump depends on the size of a mounted pump element, which may or may not be imported attached to the lubrication pump at the time of importation.

The applicable subheading for the XTS Linear Transport System, item number 81571, will be 8428.39.0000, Harmonized Tariff Schedule of the United States (“HTSUS”), which provides for “Other lifting, handling, loading or unloading machinery (for example, elevators, escalators, conveyors, teleferics): Other continuous-action elevators and conveyors, for goods or materials: Other.” The rate of duty will be free.

The applicable subheading for the motor module, part number AT2002-0250-0002, will be 8431.39.0010, HTSUS, which provides for “Parts suitable for use solely or principally with the machinery of headings 8425 to 8430: Of machinery of heading 8428: Other: Of elevators and conveyors.” The rate of duty will be free.

The applicable subheading for item 233046, the lubrication pump with a reservoir, motor, and pump element will be 8413.19.0000, HTSUS, which provides for “Pumps for liquids, whether or not fitted with a measuring device; liquid elevators; part thereof: Pumps fitted or designed to be fitted with a measuring device: Other.” The rate of duty is Free.

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/current.

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 Paul Huang at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division