CLA-2:OT:RR:NC:N2:209
Zachary Rohloff
Remco Industries
10425 Wildlife Loop SE
Osakis, MN 56360
RE: The tariff classification of electric motors from China
Dear Mr. Rohloff:
In your letter dated August 8, 2025, you requested a tariff classification ruling.
The first item under consideration is identified as an electric motor, Item Number 70-594-00 (211105A).
This item is described as a 12 Volts Direct Current (VDC) permanent magnet brushed electric motor, with
black and red leads that stripped 30 mm long. The maximum power output is 300 W. The 70-594-00 motors
are a proprietary design specifically to be coupled to the Remco Fatboy series pump heads. The motor does
not incorporate any type of gearing or any attachment at the time of importation.
The second item under consideration is identified as an electric motor, Item Number 70-594-00-24
(211105B). This item is described as 24 VCD permanent magnet brushed electric motor, with black and red
leads that stripped 30 mm long. The maximum power output is 300 W. The 70-594-00-24 motors are a
proprietary design specifically to be coupled to the Remco Fatboy series pump heads. The motor does not
incorporate any type of gearing or any attachment at the time of importation.
The third item under consideration is identified as an electric motor, Item Number 70-594-00-D
(211105A-1). This item is described as a 12 VCD permanent magnet brushed electric motor, with black and
red leads that stripped 20 mm long and include spade connectors. The maximum power output is 300 W.
The 70-594-00-D motors are a proprietary design specifically to be coupled to the Remco Fatboy series
pump heads. The motor does not incorporate any type of gearing or any attachment at the time of
importation.
The fourth item under consideration is identified as an electric motor, Item Number 70-594-115-D (216011).
This item is described as a permanent magnet brushed electric DC motor rectified to 115 Volts Alternative
Current (VAC), with a 6’ power cord with a 3-pronged plug, and 2 switch leads with spade connectors. The
maximum power output is 300 W. The 70-594-115-D motors are a proprietary design specifically to be
coupled to the Remco Fatboy series pump heads. The motor does not incorporate any type of gearing or any
attachment at the time of importation.
The applicable subheading for all four electric motors (70-594-00, 70-594-00-24, 70-594-00-D, and
70-594-115-D) will be 8501.31.4000, Harmonized Tariff Schedule of the United States (HTSUS), which
provides for Electric motors and generators (excluding generating sets): Other DC motors; DC generators,
other than photovoltaic generators: Of an output not exceeding 750W: Motors: Exceeding 74.6 W but not
exceeding 735 W. The general rate of duty will be 4 percent ad valorem.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 8501.31.4000, 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 of China, Hong
Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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 8501.31.4000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8501.31.4000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.02
in addition to subheading 8501.31.4000, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively.
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 Steven Pollichino at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division