CLA-2-85:OT:RR:NC:N2:220
Lucy Holt
Beckhoff Automation LLC
13130 Dakota Ave
Savage, MN 55378
RE: The tariff classification of motor controllers from Germany
Dear Ms. Holt:
In your letter dated December 2, 2024, you requested a tariff classification ruling.
The first item under consideration is identified as the EtherCAT Terminal, Model Number EL7037, which is described as a DIN Rail mountable enclosure having internal printed circuit board assemblies (PCBAs), LED status indicators, and front and rear facing connection terminals. The EtherCAT Terminal is intended to connect to and control electric stepper motors.
The second item under consideration is identified as the Servomotor Terminal, Model Number ELM7222-0010, which is described as a DIN Rail mountable enclosure having internal PCBAs, LED status indicators, and front facing connection terminals. The Servomotor Terminal is used to connect directly to and control electric motors.
In your letter, you state that the EtherCAT Terminal and the Servomotor Terminal contain electrical conversion circuitry that converts input electricity to a different output for the purpose of controlling the speed, torque, and/or direction of electric motors. You also suggest that the subject motor controllers are correctly classified under subheading 8504.40.4000, Harmonized Tariff Schedule of the United States (HTSUS). We agree.
The applicable subheading for the EtherCAT Terminal, Model Number EL7037, and the Servomotor Terminal, Model Number ELM7222-0010, will be 8504.40.4000, HTSUS, which provides for “Static converters: Speed drive controllers for electric motors.” 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 the World Wide Web at https://hts.usitc.gov/current.
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 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