CLA-2-84:OT:RR:NC:N1:103
Donggun Shin
Ubis Customs Service
Unit 872, 8th Floor, 326 Bongeunsa-ro, Gangnam-gu
Seoul 06143
South Korea
RE: The tariff classification of an unloading robot system from South Korea
Dear Mr. Shin:
In your letter dated June 12, 2025, you requested a tariff classification ruling on behalf of your client,
ROBOE Technologies Inc.
The merchandise under consideration is referred to as a Mobile Box-handling Robot, model number MBR-6,
and consists of a self-propelled mobile base, a singulation conveyor, and two articulated robotic arms (each
with a payload capacity of 20 kilograms). The robot is designed to unload loose cartons from shipping
containers or other cargo transport vehicles using end-effectors equipped with a vacuum pad and wide-area
roller, which is described as a friction-based roller that drags or pushes items. The cargo is unloaded onto the
conveyor mechanism, which separates and aligns the cartons into a single-file line. Once the cartons reach
the end of the conveyor, they are manually unloaded by a worker or transferred to a separate conveyor
system.
The robot can unload up to 2,000 items per hour and measures approximately 3.4 meters in length, 1.6 meters
in width, 2.3 meters in height, and weighs 2,300 kilograms. The integrated inclined conveyor is
approximately 2.5 meters in length and has a 0.9 meter per second travel speed. The robot is marketed for use
in distribution centers and warehouses but does not transport goods between two points. Its mobile base is
only used to reposition the unit.
In your submission, you suggest that the subject robot is classifiable under subheading 8428.70.0000,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other lifting, handling,
loading or unloading machinery (for example, elevators, escalators, conveyors, teleferics): Industrial robots.”
Although we agree that the merchandise is classified in heading 8428, we disagree with the suggested
subheading. The subject robot is not designed for use in industrial settings to perform intensive production
tasks in a structured environment and is more akin to a service robot that performs useful tasks (e.g., loading
and unloading) alongside people or other equipment. And while it has robotic arms, the unit is used as a
complete handling solution with a built-in singulation conveyor.
The applicable subheading for the Mobile Box-handling Robot, model number MBR-6, will be
8428.90.0390, HTSUS, which provides for “Other lifting, handling, loading or unloading machinery (for
example, elevators, escalators, conveyors, teleferics): Other machinery: Other.” The general rate of duty will
be free.
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
8428.90.0390, 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,
(for)
James Forkan
Acting Director
National Commodity Specialist Division