CLA-2-84:OT:RR:NC:CEE010:N1:104
9903.01.25; 9903.88.01; 9903.8802; 9903.88.03
Zheng Wang
Maersk Logistics & Services China Ltd
26F, No. 757, Mengzi Road, Huangpu District
Shanghai
China
RE: The tariff classification of lithium-ion battery electrolyte production equipment from China
Dear Ms. Wang:
In your letter dated October 30, 2025, on behalf of your client, Capchem Technology USA, Inc., you
requested a tariff classification ruling.
The product in question is a modular lithium-ion battery electrolyte production plant. As imported, the plant
equipment will consist of an unloading unit, hot water unit, tank farm unit, purification and filtration unit,
blending unit, water cooling unit, central control unit, pipe rack, and other components required to
interconnect the various plant modules. You state that, due to its large size, the plant equipment will be
imported unassembled in multiple containers, but in a single entry.
Your submission describes the plant’s electrolyte production process as follows. Raw materials comprised of
solvents, lithium salts, and additives, are transported by tank trucks to the plant’s unloading unit which
consists of unloading facilities, a pipe rack, and walkways. The raw materials are transferred from the
unloading unit via pumps to the tank farm for temporary storage, awaiting further processing. The tank farm
consists of storage tanks, pipe racks, and pumps. As raw materials typically arrive in a solid or semi-solid
state, they must first be heated to convert those materials into a liquid state to prepare them for future
purification, filtration, and blending that takes place elsewhere in the plant. The hot water unit, consisting of a
hot water boiler, pump, and hot water buffer vessel, provides the heated water to the raw materials packaging
tanks and the tank farm.
In the purification and filtration unit, which is composed of a purification and filtration block, pipe rack,
buffer vessels, pumps, and filters, moisture from the raw materials is removed and impurities filtered out to
meet production quality standards. Following purification and filtration, the raw materials are then transferred
to the blending unit.
The blending unit consists of three main units, blending vessels, pumps, and pipe rack. The function of the
blending unit is dispersion and stirring of purified materials by means of a mechanical agitator to create a
homogeneous and stable solution. The water-cooling unit provides cooling water to the blending unit which
is necessary to ensure the processing temperature is within the required range during mixing. It is comprised
of a water-cooling device/chiller, buffer tank, pipe rack, and pump. After blending, the finished product is
pumped via pipes into special containers to complete the process.
The central control unit consists of a control cabinet, power cabinet, network cabinet, terminal box, operating
desks and computers, cables and a grounding system. The control unit manages and controls all automation
units within the equipment and is not limited to any one functional operation in the plant.
In your submission, you suggest that all the imported plant equipment may be considered a single functional
unit within the meaning of Note 4, Section XVI, Harmonized Tariff Schedule of the United States (HTSUS),
and may therefore be classified in one heading that you claim reflects the plant’s “clearly defined function,”
i.e., mixing or blending. We disagree.
Under the HTSUS, machines and combinations of machines are classified in accordance with their function
or functions, rather than their overall purpose. In the case of large-scale plants consisting of several machines,
or multi-machine production lines, we ordinarily apply note 4 to Section XVI, HTSUS, which provides:
Where a machine (including a combination of machines) consists of individual components (whether separate
or interconnected by piping, by transmission devices, by electric cables or by other devices) intended to
contribute together to a clearly defined function covered by one of the headings in Chapter 84 or Chapter 85,
then the whole falls to be classified in the heading appropriate to that function.
In this case, we are unable to discern any singular clearly defined function for the entirety of the imported
plant equipment that would cause us to classify it under a single tariff heading. Rather the machines and
equipment in the plant perform multiple functions and therefore must be classified under those headings
appropriate to those functions, either as separate functional units or individually.
We consider the unloading unit, hot water unit, and tank farm unit to constitute a single function unit, with a
clearly defined function of treating materials by a process of a change in temperature, covered by heading
8419, HTSUS. Pursuant to GRI 1 (note 4, Section XVI) and GRI 2(a), the applicable subheading for this
functional unit will be 8419.89.9585, HTSUS, which provides for “Machinery, plant or laboratory
equipment, whether or not electrically heated (excluding furnaces, ovens and other equipment of heading
8514), for the treatment of materials by a process involving a change of temperature such as heating,
cooking, roasting, distilling, rectifying, sterilizing, pasteurizing, steaming, drying, evaporating, vaporizing,
condensing or cooling, other than machinery or plant of a kind used for domestic purposes; instantaneous or
storage water heaters, nonelectric; parts thereof: Other machinery, plant or equipment: Other: Other: Other:
Other: For other materials.” The general rate of duty will be 4.2 percent ad valorem.
The purification and filtration unit constitutes a second functional unit, with a clearly defined function of
purification/filtration of heading 8421, HTSUS. Pursuant to GRI 1 (note 4, Section XVI) and GRI 2(a), the
applicable subheading for this functional unit will be 8421.29.0065, HTSUS, which provides for
“Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or
gases; parts thereof: Filtering or purifying machinery and apparatus for liquids: Other: Other: Other: Other.”
The general rate of duty will be free.
The blending unit and water-cooling unit constitute a third functional unit, with a clearly defined function of
mixing and stirring of the purified materials and additives to create specific battery electrolyte formulations.
Mixing and stirring machines are covered in Chapter 84 under heading 8479, HTSUS. Pursuant to GRI 1
(note 4, Section XVI) and GRI 2(a), the appliable subheading for purification and filtration unit and
water-cooling unit will be 8479.82.0040, HTSUS, which provides for “Machines and mechanical appliances
having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines
and mechanical appliances: Mixing, kneading, crushing, grinding, screening, sifting, homogenizing,
emulsifying or stirring machines: Mixing, kneading or stirring machines.” The general rate of duty will be
free.
The control unit is not dedicated to the management and control of any single function unit, machine, or
equipment, but rather controls all the plant’s automation units. Pursuant to GRIs 1 and 2(a), the applicable
subheading for the control unit will be 8537.10.9160, HTSUS, which provides for “Boards, panels, consoles,
desks, cabinets and other bases, equipped with two or more apparatus of 8535 or 8536, for electric control or
the distribution of electricity, …: For a voltage not exceeding 1,000 V: Other: Other: Programmable
controllers.” The general rate of duty will be 2.7 percent ad valorem.
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 10 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 subheadings 8419.89.9585, 8421.29.0065, 8479.82.0040, and 8537.10.9160, HTSUS, listed above.
On March 12, 2025, Presidential Proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter
99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as
products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 percent upon
the value of the steel content. At the time of entry, you must report the Chapter 99 heading applicable to your
product classification, i.e. 9903.81.91, in addition to subheading 8421.29.0065, HTSUS. Derivative iron or
steel products processed in another country from steel articles melted and poured in the United States,
provided for in heading 9903.81.92, are not subject to the additional ad valorem duties.
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. For products covered
by heading 9903.81.91 this additional duty applies to the non-steel content of the merchandise. 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 subheadings 8419.89.9585, 8421.29.0065, 8479.82.0040, and 8537.10.9160, HTSUS, listed
above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8419.89.9585, 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 8419.89.9585, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 8421.29.0065 and 8479.82.0040, 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., 9903.88.01, in addition to subheading 8421.29.0065 and 8479.82.0040, HTSUS, listed
above
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8537.10.9160, 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., 9903.88.03,
in addition to subheading 8537.10.9160, 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.
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 equipment 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 Arthur Purcell at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division