CLA-2-85:OT:RR:NC:N2:212
Loan New
Fluence Energy LLC
4601 Fairfax Dr Ste 600
Arlington, VA 22203
RE: The tariff classification of a voltage converter skid from India
Dear Mr. New:
In your letter dated October 28, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified as the Medium Voltage (MV) Skid, which is described as
an electrical power transformation and distribution system. The subject device consists of three distinct
components installed within a 20-foot container. The first component is an MV transformer, which you state
is a liquid dielectric transformer with a power rating of 4,200 kVA. The second is referred to as a Ring Main
Unit (RMU)/MV switchgear panel, which is used to protect and distribute the MV power. The final
component is a Low Voltage panel, which is used to combine the AC power generated within the system as
well as protect it from any electrical fault.
In your request and through subsequent information provided, we note that the device is used as a modular
system that is ultimately installed at renewable energy plants, utility stations, industrial facilities, and
infrastructure projects. The skid, via the incorporated transformer, converts low voltage power to high
voltage power as necessary within the electrical grid. The RMU and Low Voltage panels are used to monitor
and control the power as it is altered by the transformer.
We note that we have previously ruled upon a system known as a SmartSkid under ruling N352145, dated
8/15/2025. A thorough review of the device shows multiple significant differences in form and function. The
device at issue with this request has a clearly defined function of an electric transformer while the one
discussed in N352145 functioned as a power conversion station. As such, the classification of each will
differ.
The applicable subheading for the MV Skid will be 8504.22.0080, Harmonized Tariff Schedule of the United
States (HTSUS), which provides for “Electrical transformers, static converters (for example rectifiers) and
inductors; parts thereof: Liquid dielectric transformers: Having a power handling capacity exceeding 650
kVA but not exceeding 10,000 kVA: Having a power handling capacity exceeding 2,500 kVA but not
exceeding 10,000 kVA.” The general rate of duty will be Free.
Effective August 27, 2025, Executive Order 14329 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 8504.22.0080, 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
8504.22.0080, 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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division