CLA-2-88:OT:RR:NC:N2:201
Paras Patel
Project Zephyr LLC
1309 Coffeen Avenue, Suite 1200
Sheridan, WY 82801
RE: The tariff classification of a Geranium-2 Unmanned Aerial System (UAS) from Russia
Dear Mr. Patel:
In your letter dated August 6, 2025, you requested a tariff classification ruling.
The item under consideration has been identified as a Geranium-2, Unmanned Aerial System (UAS), which
is the Russian version of the Shahed 136 UAS.
In your request you state that your company sources adversarial Unmanned Aerial Vehicles (UAVs) from
battlefield-aligned Ukrainian contacts. These UAVs (jammed, downed, or captured) remain sufficiently
intact for reverse-engineering and R&D by U.S. defense contractors in support of National Security.
The UAV will be utilized within a controlled research and development setting, focusing on electromagnetic
interference (EMI) testing to advance the capabilities of counter-UAV systems. The primary goal is to
enhance the performance and operational effectiveness of these systems for eventual deployment by the
United States and its allies, thereby serving National Defense interests. Your intent is to perform thorough
research and technical assessments to uncover system vulnerabilities, which will directly inform the design
and improvement of electronic warfare countermeasures and counter-UAS (cUAS) technologies. This effort
will contribute to national security by bolstering operational superiority in the counter-UAS domain.
The applicable subheading for the Geranium-2 will be 8806.99.0000, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for “Unmanned aircraft: Other: Other”. The column 2 rate of duty
will be 30 percent ad valorem.
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 of Russia are not
subject to reciprocal tariffs. At the time of entry, you must report the Chapter 99 heading applicable to your
product classification, i.e. 9903.01.29, in addition to subheading 8806.99.0000, HTSUS, listed above.
Please note that articles the product of the Russian Federation, as provided for in U.S. note 30(a) to
subchapter III of Chapter 99 and as provided for in the subheadings enumerated in U.S. note 30(b) raise the
Column 2 ad valorem rate of duty from 30 percent to 35 percent ad valorem.
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 Matthew Sullivan at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division