CLA-2-84:OT:RR:NC:N1:103
Edoardo Ottani
Eurofork S.p.A.
Via Roma 93
Roletto 10060
Italy
RE: The tariff classification of a pallet shuttle from Italy
Dear Mr. Ottani:
In your letter dated September 8, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified as the E4S pallet shuttle and is described as a motorized
device used in automated storage and retrieval systems. Composed primarily of steel and aluminum, the
shuttle is equipped with a battery-powered drive system, a wireless communication system, a lifting platform,
and sensors. The self-propelled shuttle travels along rails within a rack system, transporting palletized loads
between shelves and transfer points. It is capable of four-way multidirectional movement (i.e., forward,
backward, left, and right).
The body of the shuttle is 996 millimeters in width, 185 millimeters in height, and depending on the version,
up to 1,384 millimeters in length. The shuttle operates as an automated unit and can handle a maximum
payload of 1,500 kilograms, travel at speeds up to 100 meters per minute, and has a 43-millimeter lifting
stroke.
The applicable subheading for the E4S pallet shuttle will be 8427.10.8050, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for “Fork-lift trucks; other works trucks fitted with lifting or
handling equipment: Self-propelled trucks powered by an electric motor: Other: Automated guided vehicle
(AGV): Other.” The general rate of duty will be free.
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 8427.10.8050, 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 the European
Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15
percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General
duty rate. For products covered by heading 9903.01.91 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., 9903.02.20, in addition to subheading 8427.10.8050, 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 Paul Huang at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division