CLA-2-85:OT:RR:NC:N1:103
Tommy Houle
AGT Robotics
8800 Parent Blvd.
Trois-Rivières, Quebec, G9A 5E1
Canada
RE: The tariff classification of an automated welding system from Canada
Dear Mr. Houle:
In your letter dated June 26, 2025, you requested a tariff classification ruling.
The merchandise under consideration is referred to as the BeamMaster and is described as an automated
robotic welding cell for structural steel shapes, including W-shaped beams, hollow structural sections,
tapered beams, delta beams, panels, and more. The system is available in multiple configurations depending
on client requirements. In the configuration presented, the main components will include a Fanuc ARC Mate
120iD/12L welding robot, a moving boom carriage, a vision system, beam rotators, and electrical panels.
The Fanuc ARC Mate has a long-reach manipulator arm that is equipped with welding heads for gas metal
arc welding or metal-cored arc welding. It is mounted on a moving boom carriage that travels laterally along
floor-mounted rails. The beam rotators work in sync with the welding robot and are used to manipulate the
workpieces during the welding process. They are capable of handling pieces up to 48 inches in length, 20
inches in width, and 5,000 pounds in weight. The BeamMaster system is marketed as a fully autonomous
solution that can weld steel structural components with minimal human intervention and will be imported in a
single shipment.
In your request, you suggest the BeamMaster is classifiable under subheading 8515.31.0000, Harmonized
Tariff Schedule of the United States (HTSUS). We agree. While the beam rotators are listed as optional
equipment in your marketing literature, in the configuration presented they will be imported with the welding
apparatus. When the entire line is imported in a single shipment with interconnected components, it will be
classified pursuant to note 4 to Section XVI. Note 4 covers machines consisting of separate components that
are intended to contribute together to a clearly defined function. Here, the components contribute together to
perform a function covered by heading 8515.
The applicable subheading for the BeamMaster will be 8515.31.0000, HTSUS, which provides for “Electric
(including electrically heated gas), laser or other light or photon beam, ultrasonic, electron beam, magnetic
pulse or plasma arc soldering, brazing or welding machines and apparatus, whether or not capable of cutting;
electric machines and apparatus for hot spraying of metals or cermets; parts thereof: Machines and apparatus
for arc (including plasma arc) welding of metals: Fully or partly automatic.” The general rate of duty will be
1.6 percent ad valorem.
Products of Canada as provided by heading 9903.01.10 in Section XXII, Chapter 99, Subchapter III, U.S.
Note 2(j), HTSUS, other than products classifiable under headings 9903.01.11, 9903.01.12, 9903.01.13,
9903.01.14, and 9903.01.15, 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. 9903.01.10, in addition to
subheading 8515.31.0000, 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 9903.01.10. If your product is entered
duty free as originating under the USMCA, you must report heading 9903.01.14, HTSUS, in addition to
subheading 8515.31.0000, 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. 9903.01.26, in addition to subheading 8515.31.0000, HTSUS, listed above.
Merchandise is to be classified according to its condition as imported. Should the requirements of 19 CFR §
141.51 and 19 CFR § 141.58 not be met, each component of the system would be separately classified in its
own respective heading.
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