Ms. Deborah Pineda
Wahl Clipper Corporation
2900 North Locust Street
Sterling, IL 61081

RE: The tariff classification of an assembly for a shaver made in China

Dear Ms. Pineda:

In your letter dated October 24, 2012, you requested a tariff classification ruling. A sample of the assembly was submitted for our review and will be returned as requested.

The article under consideration is identified as an assembly that includes a jack board, a battery, a pc board, a switch and a motor. The assembly under consideration will be used in a number of units. Most of the units will be shavers. The units that the assembly will be used in will be for beard and mustache trimming as well as facial shaving.

In your letter you suggested classification for the assembly under heading 8501, Harmonized Tariff Schedule of the United States (HTSUS), which provides for electric motors and generators (excluding generating sets). However, the assembly in question is not just an electric motor. It is an assembly that includes items outside of heading 8501, HTSUS. The assembly concerned is the internal workings of an electric shaver. Therefore, it is an integral part of the electric shaver. Section XVI Note 2(b) instructs us to classify parts, if solely or principally used in a particular type of machine, as a part of that machine. Applying Section XVI Note 2(b) to classify the assembly which is designed for use with a particular type of machine (electric shaver), the assembly is classifiable under subheading 8510, HTSUS, which provides for shavers, hair clippers and hair-removing appliances, with self-contained electric motor; parts thereof. The applicable subheading for the assembly for use with shavers will be 8510.90.2000, HTSUS, which provides for shavers, hair clippers and hair-removing appliances, with self-contained electric motor; parts thereof: parts: parts of shavers: other parts of shavers. The rate of duty will be 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 on World Wide Web at

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Ann Taub at 646-733-3018.


Thomas J. Russo
National Commodity Specialist Division