Kevin Whitham
18 Silkbay Place Spring, TX 77382

RE: The tariff classification of a motorhome from Canada

Dear Mr. Whitham:

In your letter dated April 26, 2024, you requested a tariff classification determination ruling.

The item under consideration has been identified as a 2013 Mitsubishi Fuso FG4x4 cab-chassis motor vehicle with a 3.0-liter diesel engine built in Japan. At the time of import, the vehicle has a permanently mounted, by mechanical bolts, body installed making the vehicle a single unit. You state that the body is not designed to be removed and is not designed to be used separately from the vehicle as a standalone unit.

You state the dimensions of the vehicle are approximately 15 ft. long, 7 ft. wide, 6 ft. 5 in. high. The body is made with composite panels of foam insulation covered by fiberglass on both sides. There are four acrylic windows measuring 900mm X 500mm, three on the driver's side and one on the passenger side, all of which can be opened. There is one roof hatch 577mm X 577mm, which can be opened for ventilation. The vehicle also has one door on the passenger side for ingress and egress.

Inside the body are systems for habitation, including a 230 liter water tank, water filter, water pump, sink, shower, electric water heater, diesel air heater connected to the vehicle diesel fuel tank, batteries for electrical power, battery charger, interior lighting, DC to AC electrical inverter, electrical outlets, refrigerator, electric cooktop, coffee machine, toaster oven, a bed, two bench style seats, counters, storage compartments, and one permanently mounted table. Mounted on top of the body are three solar panels.

In your request, you suggested classification of the vehicle as two (2) separate parts, the 2013 Mitsubishi Fuso FG4x4 cab-chassis motor vehicle classified under subheading 8704.22.11, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Motor vehicle for the transport of goods: exceeding 5 metric tons but not exceeding 20 metric tons: Cab chassis, and the habitation portion in either heading 8708 as a trailer, or subheading 9406.90, HTSUS, as a Prefabricated building. These suggested classifications are incorrect. According to the information you provided, the habitation unit is permanently married to the chassis of the vehicle and cannot be easily removed without the use of an overhead crane and disconnecting the electrical and gas systems. As this habitation unit is not removable, it is not considered to be a prefabricated building or trailer. Since the vehicle and habitation unit are permanently married, the vehicle is considered a single vehicle for tariff purposes.

The applicable subheading for the motorhome will be 8703.33.0130, HTSUS, which provides for Motor cars and other motor vehicles principally designed for the transport of persons (other than those of heading 8702), including station wagons and racing cars: Other vehicles, with only compression-ignition internal combustion piston engine (diesel or semi-diesel): Of a cylinder capacity exceeding 2,500 cc.: Motor Homes. The general rate of duty will be 2.5% ad valorem.

In your submission, you requested whether the vehicle is eligible for duty free treatment under the United States Mexico Canada Agreement (USMCA).

Unfortunately, you were not able to provide the information required to calculate the Regional Value Content (RVC). If you wish to apply for a free trade agreement determination, you may request a ruling from Customs and Border Protection Headquarters regarding the RVC of your goods and eligibility for USMCA preferential treatment. Requests may be sent to:

Customs and Border Protection Valuation and Special Programs Branch Regulations and Rulings, Office of Trade 90 K. Street, NE, 10th Floor Washington, DC 20229-1177

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

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 Matthew Sullivan at [email protected].


Steven A. Mack
National Commodity Specialist Division