CLA-2-85:OT:RR:NC:N2:212
Moon Kyung-jin
JINSOL Customs Consulting & Logistic Service
129, Gaetbel-ro, Yeonsu-gu
Incheon
South Korea
RE: The tariff classification of a power module from South Korea
Dear Moon Kyung-jin:
In your letter dated September 18, 2025, you requested a tariff classification ruling on behalf of your client,
Hyundai Mobis Company, Ltd.
The merchandise under consideration is identified as the Power Module HK3, part number 37800-0E130.
The subject device is further described as a power module used to convert DC power from a battery into AC
power to drive electric motors within electric vehicle traction control systems. The device consists of
multiple Insulated Gate Bipolar Transistors (IGBT) on a ceramic substrate within an enclosure. The IGBTs
rapidly switch in order to convert the power as noted.
In your request, you suggest that the correct classification for the subject module should be 8541.29.0095,
Harmonized Tariff Schedule of the United States (HTSUS). We disagree.
The item is an assembly of transistors, resistors, spacers, substrates, and other electrical components. The
primary function is to convert DC current to AC current for use within an electric motor. By this explanation,
the subject device meets the definition of a rectifying apparatus per the terms of the tariff, specifically within
heading 8504, HTSUS. As such, classification within heading 8541, HTSUS, is not applicable.
The applicable subheading for the Power Module HK3, part number 37800-0E130, will be 8504.40.9570,
HTSUS, which provides for “Electrical transformers, static converters and inductors…: Static converters:
Other: Inverters.” The general rate of duty will be Free.
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 South Korea
will be subject to an additional ad valorem rate of duty of 15 percent. At the time of entry, you must report
the Chapter 99 heading applicable to your product classification, i.e. 9903.02.56, in addition to subheading
8504.40.9570, 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 Luke LePage at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division