CLA-2-87:OT:RR:NC:N2:201
Thomas Brennan
Craggy Tops LLC
8625 Silverberry Lane
Bozeman, MT 59718
RE: The tariff classification of a motorhome from France
Dear Mr. Brennan:
In your letter dated May 2, 2025, you requested a tariff classification ruling.
The item under consideration has been identified as a 1997 Renault Midliner M210 4x4 cab-chassis with a
permanent RV habitat, VIN VF640BCA00000018.
The vehicle is powered by a 6.18 Liters (6,180 CC) diesel engine. The vehicle’s habitation unit is
permanently mounted by mechanical bolts and, you claim, is not designed to be removed or be used
separately from the vehicle as a standalone unit. You state that the vehicle originally served as a French Fire
Truck until 2020. The motorhome is designed to carry a family of up to six (6) individuals, and provides a
permanently mounted area to sleep, cook, bath, and seek shelter from inclement weather.
The motorhome is approximately 26 feet long, 8 feet wide, and 11 ½ feet tall. The motorhome has two front
seats with seat belts and a bench rear seat with four seat belts. The cab of the motorhome has 4 doors for
ingress/egress of passengers. The motorhome has a door on the passenger’s side into the habitat for
ingress/egress as well as four acrylic windows, three on the passenger’s side and one on the driver’s side, all
of which can be opened.
The motorhome has one roof hatch which can be opened for additional ventilation. Inside the body are
systems for habitation, including a fridge, two-burner stove, toilet, hot water system, two 40 gallon clean
water tanks, one 40 gallon grey water tank, sink, shower, water pump, batteries for electrical power, electrical
inverter, interior lighting, diesel heater, a convertible queen bed into a bench style table, two bunk beds,
kitchen counter, refrigerator, storage compartments, and storage drawers. Mounted on top of the body are
solar panels.
The external lights on the side and rear of the body are tied into the vehicle electrical system. In addition,
there is an electric cable from the vehicle battery to the body which allows for the body electrical system to
charge while the engine is running.
In your request you suggest classification in 8703.33.0130, Harmonized Tariff Schedule of the United States
(HTSUS). We concur.
The applicable subheading for the 1997 Renault Midliner M210 4x4 cab-chassis with a permanent RV
habitat, VIN VF640BCA00000018 will be 8703.33.0130, HTSUS, which provides for “Motor cars and other
motor vehicles principally designed for the transport of persons….: 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.
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. At this time products from all 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
8703.33.0130, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 https://hts.usitc.gov/.
Please note, this classification has no effect on the importability of any vehicle or vehicle parts/accessories
deemed restricted, including motor vehicles not conforming to Federal Safety and Emission Standards. Any
questions regarding the importation of these vehicles and or parts may be directed to the National Highway
Traffic Safety Administration (NHTSA) at 888-327-4236 and/or the Environmental Protection Agency
(EPA) at 202-272-0167.
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].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division