CLA-2-85:OT:RR:NC:N2:212
Kaitlyn Howe
Orscheln Products LLC
1177 North Morley Street
Moberly, MO 65270
RE: The tariff classification of a position sensor PCBA from India
Dear Ms. Howe:
In your letter dated October 24, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified by part number E284-00 and is described as a Printed
Circuit Board Assembly (PCBA) that will be incorporated within a rotary position sensor. The subject PCBA
consists of a rotation sensor Integrated Circuit (IC) mounted onto a board along with various other passive
components. The sensor IC functions on the Hall-Effect principal as it creates a magnetic field that, when
broken by the presence of a metal object (i.e. gear component), creates an electrical signal that is sent to a
control unit for interpretation. In this way, it functions as a transducer. The subject sensor PCBA is used
within various position sensors in heavy construction equipment, agricultural machinery, and other vehicles.
In your request, you suggest that the correct classification for the subject PCBA is 8542.31.0050,
Harmonized Tariff Schedule of the United States (HTSUS). We disagree.
Heading 8542, HTSUS, provides for electronic integrated circuits and their parts. However, it does not
provide for an assembly of discrete electronic elements and/or components forming a PCBA. The item at
issue is considered a finished functional apparatus with a specific function which is manufactured beyond
that of standalone integrated circuits. As such, classification within heading 8542, HTSUS, is not appropriate.
The applicable subheading for the Sensor PCBA, part number E284-00, will be 8543.70.4500, HTSUS,
which provides for “Electrical machines and apparatus, having individual functions, not specified or included
elsewhere in this chapter; parts thereof: Other machines and apparatus: Electric synchros and transducers;
flight data recorders; defrosters and demisters with electric resistors for aircraft: Other.” The general rate of
duty will be 2.6% ad valorem.
Effective August 27, 2025, Executive Order 14339 imposed additional duties on products from India. At this
time, products of India provided by heading 9903.01.84, except for products described in headings
9903.01.85 – 9903.01.89, will be subject to an additional ad valorem rate of duty of 25 percent. At the time
of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.84, in
addition to subheading 8543.70.4500, 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 India will be
subject to an additional ad valorem rate of duty of 25 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.26, in addition to subheading
8543.70.4500, 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)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division