Brian Sell
Marine Canada Acquisition Inc.
dba Seastar Solutions
3831 No. 6 Road
Richmond, BC V6V 1P6

RE: The tariff classification of a pump control module from China

Dear Mr. Sell:

In your letter dated March 20, 2018 you requested a tariff classification ruling.

The merchandise under consideration is identified as the Pump Control Module (PCM), part number EM1200, and consists of a circuit board assembly mounted within a molded plastic enclosure. The enclosure is equipped with various plugs, sockets, and terminals which are used to connect the PCM to electronic steering systems in marine vessels/pleasure or commercial boat applications.

The PCM is connected to the helm electronic power steering motors, the power steering pumps, the engine electrical network and ignition, and the autopilot if installed. In use, the subject PCM receives wheel movement messages from the helm and electrically controls the hydraulic steering pumps to steer the vessel.

In your letter, you indicate that the classification of the EM1200 pump control module should fall under subheading 8413.91.9050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of a hydraulic fluid power pump, would be consistent with the finding in NY Ruling N137235. However, the article at issue differs from the control module in that ruling which is incorporated into a type of pumping machine and is an integral part of the mechanism used to create hydraulic pressure. The EM1200 pump control module is not incorporated into the power steering pumps. It is a separate article that send signals to the pumps. Thus, the EM1200 pump control module is not classifiable as a part of a pump and instead, should be classified in accordance with Note 2a to Section XVI.

The applicable subheading for the Pump Control Module, part number EM1200 will be 8537.10.9170, HTSUS, which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Other.” The rate of duty will be 2.7 percent ad valorem.

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 Karl Moosbrugger at


Steven A. Mack
National Commodity Specialist Division