CLA-2-85:OT:RR:NC:N2:220
John Peterson
Neville Peterson LLP
701 Fifth Avenue, Suite 4200-2159
Seattle, WA 98104
RE: The tariff classification of a programmable controller and limit switch from Mexico
Dear Mr. Peterson:
In your letter dated May 4, 2025, you requested a tariff classification ruling.
The first item under consideration is identified as the Multi-Function Control Panel (Controller), Model
41A7185-1, which is described as a plastic enclosure housing multiple printed circuit board assemblies, four
front facing electrical switches, and a front facing plastic switch operator cover. In use, the Controller is
mounted to the wall to electrically control the operation of a garage door. The Controller is said to be
programmable, in that it can communicate and synchronize with keyless openers, control and/or disable the
keyless openers, and adjust the timing of lights.
The second item under consideration is identified as the Limit Switch Assembly, Model 41D3452, which is
described as a plastic housing with two adjustable drive contacts and a main drive gear contact. In use, the
Limit Switch Assembly is mounted to a garage door opener to facilitate the upper and lower limits of the
door position to prevent injury or damage.
In your letter, you suggest the Controller is classifiable as a panel or distribution board under subheading
8537.10.9150, Harmonized Tariff Schedule of the United States (HTSUS). As the subject Controller is
neither a panel board nor a distribution board, but instead is considered a programmable controller, we agree
to the eighth digit only. You also suggest that the Limit Switch Assembly is classifiable under subheading
8536.50.9020, HTSUS. As the Limit Switch Assembly is not an electrical switch with rotary-type actuation,
but instead is a limit switch, we agree to the eighth digit only.
The applicable subheading for the Multi-Function Control Panel, Model 41A7185-1, will be 8537.10.9160,
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: Programmable controllers”. The general rate of duty will be 2.7
percent ad valorem
The applicable subheading for the Limit Switch Assembly, Model 41D3452, will be 8536.50.9055, HTSUS,
which provides for “Electrical apparatus for switching or protecting electrical circuits, or for making
connections to or in electrical circuits (for example, switches…), for a voltage not exceeding 1,000 V: Other
switches: Other: Other: Limit.” The general rate of duty will be 2.7 percent ad valorem.
Products of Mexico as provided by heading 9903.01.01 in Section XXII, Chapter 99, Subchapter III, U.S.
Note 2(a), HTSUS, other than products classifiable under headings 9903.01.02, 9903.01.03, 9903.01.04, and
9903.01.05, HTSUS, will be subject to an additional 25 percent ad valorem rate of duty. At the time of entry,
you must report the applicable Chapter 99 heading, i.e. 9903.01.01, in addition to subheadings 8537.10.9160
and 8536.50.9055, HTSUS, listed above. Articles that are entered free of duty under the terms of general
note 11 to the HTSUS (U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set forth in
subchapter XXIII of Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be subject to the
additional ad valorem duties provided for in heading 9903.01.01. If your product is entered duty free as
originating under the USMCA, you must report heading 9903.01.04, HTSUS, in addition to subheadings
8537.10.9160 and 8536.50.9055, HTSUS.
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. Your product falls within an excepted
subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.01.27, in addition to subheading 8537.10.9160, 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 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,
(for)
Steven A. Mack
Director
National Commodity Specialist Division