Edward Fishburne
Volvo Car USA, LLC
1801 Volvo Car Drive
Ridgeville, SC 29472

RE: The tariff classification of the Electronic Rear Axle Drive from Italy

Dear Mr. Fishburne:

In your letter dated October 31, 2018 you requested a tariff classification ruling.

The merchandise under consideration is identified as the Electronic Rear Axle Drive (ERAD), Part Number 360126304, which consists of a three-phase permanent-magnet synchronous electric motor, a transmission, and a clutch. You state the motor is rated at 60 kW output and also functions as a regenerative breaking motor by converting current when opposite rotation is applied.

In use, the ERAD assembly is mounted on the rear subframe of the vehicle. Initial power is provided by a 12-kWh lithium-ion battery pack. The Inverter Electric Rear Axle Drive Module (IEM) converts the battery’s DC current to three phase AC current to provide power to the ERAD. The transmission and a clutch can mechanically disengage the ERAD for the purpose of electric propulsion and power boost to assist the front motor on a vehicle. You state that the subframe, IEM, and battery are not imported with the ERAD.

The applicable subheading for the Electronic Rear Axle Drive (ERAD), Part Number 360126304 will be 8501.52.8040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric motors and generators (excluding generating sets): Other AC motors, multi-phase: Of an output exceeding 750 W but not exceeding 75 kW: Other: Other.” The general 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 Karl Moosbrugger at


Steven A. Mack
National Commodity Specialist Division