CLA-2-85:OT:RR:NC:N2:212
Loan New
Fluence Energy LLC
4601 Fairfax Dr, Ste 600
Arlington, VA 22203
RE: The tariff classification of an AC conversion platform from Vietnam
Dear Mr. New:
In your letter dated August 7, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified as the Fluence SmartSkid, which is described as an
Alternating Current (AC) based energy storage platform. The subject device consists of AC conversion
hardware, an HVAC system, a fire panel, and battery management electronics. After importation, the
platform is combined with the Smartstack lithium battery system. The SmartSkid functions as the functional
power conversion element of the system, taking the Direct Current (DC) stored by the batteries and
converting it to AC that can be readily used by the electrical grid or other installation. The HVAC, fire
control, and battery management systems only enhance these functions and would be considered secondary
for classification purposes.
In your request, you suggest that the correct classification for the subject platform is under subheading
8504.40, Harmonized Tariff Schedule of the United States (HTSUS). We agree.
The applicable subheading for the Fluence SmartSkid will be 8504.40.9570, HTSUS, which provides for
“Electric transformers, static converters and inductors…: Static converters: Other: Inverters.” 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 of Vietnam will be
subject to an additional ad valorem rate of duty of 20 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.69, in addition to subheading
8504.40.9570, 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 Luke LePage at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division