CLA-2-85:OT:RR:NC:N2:220
Minsung Kim
Korea Electric Terminal Co., Ltd.
(21999) 38, Gaetbeol-ro,
Yeonsu-gu, Incheon 21999
Korea
RE: The tariff classification of an electrical protection device from Vietnam
Dear Mr. Kim:
In your letter dated March 26, 2025, you requested a tariff classification ruling on behalf of your client,
Mobis North America LLC.
The merchandise under consideration is identified as the Battery Disconnect Unit (BDU) that is described as
a molded plastic housing containing numerous electrical busbars, three electrical relays, two current sensors,
two wire harnesses, and various fastening hardware, all of which is mounted to a molded plastic base. In use,
the BDU monitors the electrical current flowing from an electric vehicle battery pack and performs a
disconnect when abnormal draw is detected that protects the vehicle from thermal runaway due to
overcurrent conditions.
The applicable subheading for the Battery Disconnect Unit will be 8537.10.9170, Harmonized Tariff
Schedule of the United States (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.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other
countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must
report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to
subheading 8537.10.9170, HTSUS, listed above.
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