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 223010A-F. This item is
described as a 12 Volts Direct Current (VDC), permanent magnet brushed electric motor, with black and red
leads that stripped 30mm long. The 223010A-F has a front end bell housing for Remco Zeus series, a rear
end bell includes mechanical driven fan for cooling, and a standard mounting base. The maximum power
output is 420 W. The 223010A-F motors are a proprietary design specifically to be coupled to the Remco
Zeus 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 223010A-SW. This
item is described as a 12 VDC, permanent magnet brushed electric motor, with covered 10awg black and red
leads that stripped 18’ long that include battery clips and a 50amp fuse. The 223010A-SW has front end bell
housing for Remco Zeus series, a rear end bell that includes an integrated on/off switch circuit, and a
standard mounting base. The maximum power output is 420 W. The 223010A-SW motors are a proprietary
design specifically to be coupled to the Remco Zeus 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 223010B-F. This item is
described as a 24 VDC, permanent magnet brushed electric motor, with black and red leads that stripped
30mm long. The 223010B-F has a front end bell housing for Remco Zeus series, a rear end bell that includes
mechanical driven fan for cooling, and a standard mounting base. The maximum power output is 420 W.
The 223010B-F motors are a proprietary design specifically to be coupled to the Remco Zeus 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 223010B-FS. This item
is described as a 24 VDC permanent magnet brushed electric motor, with black and red leads that are
integrated into a solid state relay switch circuit which takes the amperage load when a pressure switch is
wired into the pump. The 223010B-FS has a front end bell housing for Remco Zeus series, a rear end bell
that includes mechanical driven fan for cooling, and standard mounting base. The maximum power output is
420 W. The 223010B-FS motors are a proprietary design specifically to be coupled to the Remco Zeus series
pump heads. The 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 223010C-SW. This item is
described as a permanent magnet brushed electric DC motor rectified to 115 Volts Alternating Current
(VAC) with integrated on/off switch circuit and 6' power cord with a 3-pronged plug. The 223010C-SW has
a front end bell housing for Remco Zeus series, and standard mounting base. The maximum power output is
420 W. The 223010C-SW motors are a proprietary design specifically to be coupled to the Remco Zeus
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 five electric motors (223010A-F, 223010A-SW, 223010B-F, 223010B-FS,
and 223010C—W) 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