CLA-2-85:OT:RR:NC:N1:103
Tommy Houle AGT Robotics 8800 Parent Blvd. Trois-Rivières, Quebec, G9A 5E1 Canada RE: The tariff classification of an automated robotic welding cell from Canada Dear Mr. Houle: In your letter dated September 23, 2025, you requested a tariff classification ruling. The merchandise under consideration is referred to as the BLOK Automated Welding System and is described as a partially automatic robotic arc welding cell designed for fabricating large-scale structural steel, including welding bridge cross-frames, trailer frames, metal skids, and more. Its main components include a pair of robotic welding robots, a multi-axis rail system, and rotators. Dual Fanuc Arc Mate 120iD/12Lwelding robots (configured for gas metal arc welding or metal-cored arc welding) are mounted on a base that contains a power source, a controller unit, and a cooling system. This unit will sit atop the rail system, which is connected to rotators or positioners that manipulate workpieces during the welding process. While the rotators are optional equipment, they will be imported with the welding apparatus in the subject configuration. When the entire welding cell is imported in a single shipment with interconnected components, it will be classified pursuant to note 4 to Section XVI. Note 4 covers machines consisting of separate components that are intended to contribute together to a clearly defined function. Here, the components contribute together to perform a function covered by heading 8515. The applicable subheading for the BLOK Automated Welding System will be 8515.31.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric (including electrically heated gas), laser or other light or photon beam, ultrasonic, electron beam, magnetic pulse or plasma arc soldering, brazing or welding machines and apparatus, whether or not capable of cutting; electric machines and
apparatus for hot spraying of metals or cermets; parts thereof: Machines and apparatus for arc (including plasma arc) welding of metals: Fully or partly automatic.” The general rate of duty will be 1.6 percent ad valorem. Products of Canada as provided by heading 9903.01.10 in Section XXII, Chapter 99, Subchapter III, U.S. Note 2(j), HTSUS, other than products classifiable under headings 9903.01.11, 9903.01.12, 9903.01.13, 9903.01.14, and 9903.01.15, HTSUS, will be subject to an additional 35 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.10, in addition to subheading 8515.31.0000, HTSUS, listed above. Articles that are entered free of duty under the terms of general note 11 to the HTSUS (U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set forth in subchapter XXIII of Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be subject to the additional ad valorem duties provided for in heading 9903.01.10. If your product is entered duty free as originating under the USMCA, you must report heading 9903.01.14, HTSUS, in addition to subheading 8515.31.0000, HTSUS. 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 Canada are not subject to reciprocal tariffs. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e., 9903.01.26, in addition to subheading 8515.31.0000, HTSUS, listed above. Merchandise is to be classified according to its condition as imported. Should the requirements of 19 CFR § 141.51 and 19 CFR § 141.58 not be met, each component of the system would be separately classified in its own respective heading. 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 Designated Official Performing the Duties of the Division Director National Commodity Specialist Division