CLA-2-85:OT:RR:NC:N2:220
Elsion Constansia
EVBox BV
Kabelweg 47
1014 BA Amsterdam
Netherlands
RE: The tariff classification of electric vehicle charging station from the Netherlands
Dear Mr. Constansia:
In your letter dated July 30, 2020 you requested a tariff classification ruling.
The merchandise under consideration is identified as the EVBox Iqon, which is described as an electric vehicle charging station consisting of an outdoor enclosure, insulated electrical cables with charging connectors, internal control electronics, a user display interface, and a metering system. Internally, the EVBox Iqon is equipped with numerous DIN rail mounted electrical apparatus, such as terminal blocks, relays, and contacts. Also incorporated into the charging station are multiple printed circuit board assemblies that control the distribution of electricity to one or more vehicles, supply network communications to a host system, communicate with the vehicle being charged, and control of the user interface. Lastly, the EVBox Iqon has an integrated electrical protection feature that is identified as the Charging Circuit Interruption Device, which detects and halts vehicle charging functions when electrical faults are present.
In use, the EVBox Iqon is attached through the charging cables to the vehicle charge port. After credentials/payment is verified through the user interface, the EVBox Iqon supplies 240 VAC to the vehicle for the purpose of charging the batteries. If two vehicles are being charged simultaneously, or if multiple EVBox Iqons are installed in a charging group, the charge controller(s) adjust the amperage supplied to each vehicle for load balancing. You state that the EVBox Iqon accepts two forms of payment for the electricity distributed. The first method is coordinated via an RFID card that is billed through the charging management system, and the second method involves users scanning a QR code on the front panel display and providing payment via a website or an application present in the charging management system.
In your request, you suggest the EVBox Iqon is accurately described as a static converter under subheading 8504.40, Harmonized Tariff Schedule of the United States (HTSUS). We disagree.
Based on the information provided, the EVBox Iqon does not convert, alter, or rectify the electricity supplied to the vehicle. While there is an internal power supply that converts mains AC input power to 12 VDC, this electricity is used to power the internal control circuitry and user interface and is not supplied to the attached vehicle. In our view, the EVBox Iqon’s function is to control and distribute electricity while providing electrical protection measures throughout the charging process. As such, classification of the EVBox Iqon under subheading 8504.40, HTSUS, is not appropriate.
The applicable subheading for the EVBox Iqon 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 general 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 the World Wide Web at https://hts.usitc.gov/current.
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 [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division