CLA-2-85:OT:RR:NC:N2:212
Moon Kyung-jin
JINSOL Customs Consulting & Logistic Service
129, Gaetbel-ro, Yeonsu-gu,
Incheon
South Korea
RE: The tariff classification of a busbar from Korea
Dear Moon Kyung-jin:
In your letter dated November 2, 2025, you requested a tariff classification ruling on behalf of your client,
Hyundai Mobis Company, Ltd.
The merchandise under consideration is identified by part number CV37516420 and further described as a
Bus Bar-Negative Junction. The subject busbar is comprised of a length of copper conductor that is insulated
with Mica tape. Each end of the bar has connection holes that are formed through a press die and covered
with rubber. You state that the bar is used in an automotive battery system in order to provide a connection
and allow for current flow between the Powertrain Relay Assembly (PRA) and the battery system. Though
not specifically rated for a voltage, you state that testing indicates that the insulation withstand testing shows
no breakdown until 2650 V (AC) and 4240 V (DC).
In your request, you suggest that the correct classification for the busbar should be 8536.90.8585,
Harmonized Tariff Schedule of the United States (HTSUS). We disagree.
The requested heading covers apparatus used to protect, switch, or make connections in electrical circuits. As
evidence, you provide ruling N033554, which you state supports your position. However, we find that the
subject bar significantly differs from the item at issue in the noted ruling in both form and function. In our
view, the terms of heading 8544, HTSUS, more accurately describe the bar as it is electrically insulated and
appears to be primarily used to facilitate the flow of electricity. As such, heading 8536, HTSUS, is not
applicable.
The applicable subheading for the Bus Bar – Negative Junction, part number CV37516420, will be
8544.60.2000, HTSUS, which provides for “Insulated (including enameled or anodized) wire, cable
(including coaxial cable) and other insulated electric conductors, whether or not fitted with connectors;
optical fiber cables, made up of individually sheathed fibers, whether or not assembled with electric
conductors or fitted with connectors: Other electric conductors, for a voltage exceeding 1,000 V: Fitted with
connectors.” The general rate of duty will be 3.7% ad valorem.
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 South Korea will
be subject to an additional ad valorem rate of duty of 15 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.56, in addition to subheading
8544.60.2000, 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