CLA-2-85:OT:RR:NC:N2:220
Thomas Varghese
Danlaw Inc.
41131 Vincenti Ct.
Novi, MI 48375
RE: The tariff classification of an electric vehicle charging station from India
Dear Mr. Varghese:
In your letter dated March 17, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified as the Electric Vehicle Supply Equipment (EVSE), which
is described as a wall mountable enclosure having an input cable and a 25-foot output cable with an SAE
connector. The EVSE incorporates two printed circuit board assemblies, labelled the LED Board and the
Main Board, where the latter distributes electricity by opening and closing relay(s) for the purpose of
charging the connected vehicle’s batteries. However, we note that the EVSE is limited to supplying
unconditioned AC power to the vehicle and no power conversion occurs within the device as it takes in 240
VAC and distributes 240 VAC via the output cable. The EVSE is imported with a cradle/holster, mounting
hardware, and a CleverKey ODB module.
In your letter, you suggest the EVSE is properly classified under subheading 8504.40.9540, Harmonized
Tariff Schedule of the United States (HTSUS). We disagree. Heading 8504 provides for electrical
transformers, static converters, and inductors. As the subject EVSE does not convert or alter the input
electricity to a converted output, subheading 8504.40.9540. HTSUS, is not appropriate.
The applicable subheading for the Electric Vehicle Supply Equipment 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 collage 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.
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