CLA-2-85:OT:RR:NC:N2:220
Douglas Emley
3312 Newell St.
San Diego, CA 92106
RE: The tariff classification of electric motors from China
Dear Mr. Emley:
In your letter dated May 11, 2025, you requested a tariff classification ruling.
The first item under consideration is identified as the QS273 V3 Electric Car Wheel Hub Motor, which is
described as a 72 V brushless DC (BLDC) electric motor having a single axle and a maximum power output
of 26.5 kW. The QS273 V3 Motor is intended to be used with a vehicle for propulsion.
The second item under consideration is identified as the QS268 90H Electric Motor, which is described as a
72 V BLDC electric motor having a double axle and a maximum power output of 50 kW. The QS273 V3
Motor is intended to be used with a vehicle for propulsion.
The applicable subheading for the QS273 V3 Electric Car Wheel Hub Motor and the QS268 90H Electric
Motor will be 8501.32.2000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for
“Electric motors…: Other DC motors…: Of an output exceeding 750 W but not exceeding 75 kW: Motors:
Exceeding 750 W but not exceeding 14.92 kW". The general rate of duty will be 2.9%.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 8501.32.2000, HTSUS, listed above.
Effective May 3, 2025, Presidential proclamation 10908 imposed additional tariffs on certain automobile
parts. Additional duties on automobile parts of 25 percent are reflected in Chapter 99, heading 9903.94.05,
as provided in subdivision (g) of U.S. note 33 to this subchapter. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.94.05, in addition to subheading
8501.32.2000, HTSUS, listed above.
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. 9903.01.33, in addition to subheading 8501.32.2000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8501.32.2000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.02,
in addition to subheading 8501.32.2000, 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,
(for)
Steven A. Mack
Director
National Commodity Specialist Division