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 M582B-S (M12-58B-A).
This item is described as a 12 VDC permanent magnet brushed electric motor, with black and red leads that
includes a 2-pin SAE connector. The maximum power output is 144W. The M582B-S motors are designed
to be used to drive diaphragm pump heads with the Remco 5500 series of sprayer pumps. This 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 M582-S (M12-58B).
This item is described as a 12 VDC permanent magnet brushed electric motor, with black and red leads that
include two spades and one 2-pin SAE connector. The maximum power output is 144W. The M582-S
motors are designed to be used to drive diaphragm pump heads with the Remco 5500 series of sprayer
pumps. This 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 224008. This item is
described as a 72 VDC permanent magnet brushed electric motor, with black and red leads that includes a
2-pin SAE connector. The maximum power output is 130W. The 224008 motors are designed to be used to
drive diaphragm pump heads with the Remco 5500 series of sprayer pumps. This 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 M70-563-JDS-REM.
This item is described as a 12 VDC permanent magnet brushed electric motor, with black and red leads that
includes a 2-pin SAE connector. The maximum power output is 180W. The M70-563-JDS-REM motors are
designed to be used to drive diaphragm pump heads with the Remco 5500 series of sprayer pumps. This
motor does not incorporate any type of gearing or any attachment at the time of importation.
The fifth item under consideration is identified as an electric motor, item number M70-563-JDS-REM-D.
This item is described as a 12 VDC permanent magnet brushed electric motor, with black and red leads that
include two spades and one 2-pin SAE connector. The maximum power output is 180W. The
M70-563-JDS-REM motors are designed to be used to drive diaphragm pump heads with the Remco 5500
series of sprayer pumps. This motor does not incorporate any type of gearing or any attachment at the time
of importation.
The applicable subheading for all five electric motors (M582B-S, M582-S, 224008, M70-563-JDS-REM, and
M70-563-JDS-REM-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