CLA-2-87:OT:RR:NC:N2:201
Kensie Sugama
Trade Pacific PLLC
700 Pennsylvania Ave SE, Suite 500
Washington, DC 20003
RE: The tariff classification of an all-terrain crane from China
Dear Mr. Sugama:
In your letter dated September 30, 2025, you requested a tariff classification ruling of an all-terrain crane on
behalf of your client, SANY America Inc., Peachtree City, Georgia.
The item under consideration has been identified as an all-terrain crane, model SAT700A-3.1. The
SAT700A-3.1 has the following specifications:
Max capacity: 70 US tons
Boom Length: 164 feet
JLB Length: 52 feet
Max Tip Height: 218 feet
Engine: Cummins L9 off-road in-line six diesel engine
Transmission: Allison 4500SP 6-speed AT with three phase torque converter and planetary gear
Axle: Kessler axles with high bearing capacity and reliable quality. Hydro pneumatic suspension
system with optional 6×6 drive mode
Tire Size: 385/95R25 - 445/95R25 12'11" - 525/95R25
Length: Approximately 52.7 feet
Width: Approximately 9.8 feet
Height: Approximately 10.7 feet
Convertible Dual Passenger Seats that fold into a sleeping berth
10.1-inch Touchscreen Display with integrated backup camera and multimedia controls
Wide-Angle Heated Rearview Mirrors for enhanced road visibility in all weather conditions
High-Intensity LED Headlamps & Fog Lights, ensuring clear, reliable lights for nighttime and
low-visibility driving
Fully Automatic Climate Control System (HVAC) for optimal cabin temperature in any environment
Maximum transport weight of 40 tons (88,180 lbs.)
You state that the crane is designed for precision and operator convenience. The SAT700A-3.1 features a
wireless remote-control system allowing full operation of all crane functions for precise adjustments; an
anti-electromagnetic interference module for reliability; a climate-controlled, tiltable, cab with ergonomic
seating, intuitive controls, and low noise insulation; and multiple cameras to enhance awareness.
The lifting boom, hydraulics, driver’s cab, operator’s cab, and counterweight are installed on top of a custom
multi-axle wheeled chassis. The chassis is custom designed to be specifically used with the integrated
telescopic boom. The machine can travel on roads using the driver’s cab, but the operator’s cab and crane
cannot move under load or be in function while the machine is moving. That is, the crane’s travel function is
secondary to its primary function of lifting and handling loads at construction and industrial sites.
The applicable subheading for the Crane Truck will be 8705.10.0010, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for “Special Purpose motor vehicles, other than those principally
designed for the transport of persons or goods … Mobile cranes: Cable operated.” The duty rate is Free.
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 8705.10.0010, 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 8705.10.0010, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8705.10.0010, 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 8705.10.0010, 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 Matthew Sullivan at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division