CLA-2:OT:RR:NC:N2:209
Adam Klaser
C.H. Robinson
26555 Evergreen Rd, #300
Southfield, MI 48076
RE: The tariff classification of housings for 5 electric motors from Vietnam
Dear Mr. Klaser:
In your letter dated August 12, 2025, you requested a tariff classification ruling.
The first item under consideration is described as a DC Motor Housing (EZ8), item number 137033-01. The
housing is made of low carbon steel and is used to house a DC motor, which is to be applied to a fuel transfer
pump assembly, with a power rating of over 18.65 Watts.
The second and third items under consideration are described as DC Motor Housings (G20) for explosion
proof motors, item numbers 162224-01 and 170355-01. The housings are made of low carbon steel and are
used to house DC motors, which are to be applied to a fuel transfer pump assemblies, with a power rating of
over 18.65 Watts.
The fourth item under consideration is described as an AC Motor Housing (M1115), item number 119056-1.
The housing is made of low carbon steel and is used to house an AC motor, which is to be applied to a fuel
transfer pump assembly, with a power rating of over 18.65 Watts.
The fifth item under consideration is described as a DC Motor Housing (M150), item number 119164-01.
The housing is made of low carbon steel and is used to house a DC motor, which is to be applied to a fuel
transfer pump assembly, with a power rating of over 18.65 Watts.
The applicable subheading for each of the 5 electric motor housings, item numbers 137033-01, 162224-01,
170355-01, 119056-1, and 119164-01, will be 8503.00.9520, Harmonized Tariff Schedule of the United
States (HTSUS), which provides for Parts suitable for use solely or principally with the machines of heading
8501 or 8502: Other: Parts of motors. The general rate of duty will be 3 percent ad valorem.
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter
99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as
products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 percent upon
the value of the steel content. At the time of entry, you must report the Chapter 99 heading applicable to your
product classification, i.e. 9903.81.91, in addition to subheading 8503.00.9520, HTSUS. Derivative iron or
steel products processed in another country from steel articles melted and poured in the United States,
provided for in heading 9903.81.92, are not subject to the additional ad valorem duties.
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. For products covered by heading 9903.81.91
this additional duty applies to the non-steel content of the merchandise. 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
8503.00.9520, 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 Steven Pollichino at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division