CLA-2-85:OT:RR:NC:N1:103
Julie Yan
Pan American Automotive Parts Trading LLC
602 Brents Road
Lewisburg, TN 37091
RE: The tariff classification of a battery housing from Serbia
Dear Ms. Yan:
In your letter dated May 12, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified as a battery housing, model number BTM37-5P7500, and
is described as the bottom enclosure for an electric vehicle battery assembly. It is created using a die casting
process from an aluminum alloy meeting the European standard EN AC-43500 (also designated as
AlSi10MnMg). The housing is contoured to a vehicle chassis and has shallow pockets, recessed trays,
mounting points, and other open spaces that collectively hold and protect a battery module subassembly that
is installed post-importation. Afterwards, an upper panel assembly (that is not part of this request) is installed
and the finished battery assembly is mounted inside a vehicle. You state that the battery housing will only
hold components for the battery assembly and will not contain any mechanical or electrical components for
other systems in the vehicle.
The applicable subheading for the battery housing, model number BTM37-5P7500, will be 8507.90.8000,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric storage batteries,
including separators therefor, whether or not rectangular (including square); parts thereof: Parts: Other.” The
general rate of duty will be 3.4 percent ad valorem.
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
8507.90.8000, HTSUS, listed above. Articles that are eligible for special tariff treatment under the United
States-Mexico-Canada Agreement (USMCA), other than automobile knock-down kits or parts compilations;
or are not parts of passenger vehicles (sedans, sport utility vehicles, crossover vehicles, minivans or cargo
vans) and light trucks, will not be subject to the additional ad valorem duties provided for in heading
9903.94.05. If your product is entered duty free as originating under the USMCA, you must report heading
9903.94.06, HTSUS, in addition to subheading 8507.90.8000, 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 8507.90.8000, 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/.
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 Paul Huang at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division