CLA-2-84:OT:RR:NC:N1:103
Lucia Logrillo
Fameccanica Data S.p.A. a socio unico
Via Aterno 136
Sambuceto di S. Giovanni Teatino 66020
Italy
RE: The tariff classification of an automated elevator from Italy
Dear Ms. Logrillo:
In your letter dated November 5, 2025, you requested a tariff classification ruling.
The merchandise under consideration is referred to as a Mastless Lift Cell and is described as an automated
elevator used in an automated warehouse storage system. The warehouse system where the elevator will be
installed will have lifting and handling equipment integrated into a structure with multiple levels and aisles.
Within the structure, the subject elevator will be installed inside a vertical column referred to as a “lift cell.”
The elevator moves vertically on a pair of fixed guide rails and uses a belt-driven system to lift and lower a
platform. It is imported as a collection of assemblies, which includes a top drive assembly, a bottom drive
assembly, a carriage assembly, and a Load Handling Device (LHD) assembly. The top drive assembly
consists of a base plate with two idler pulleys and is mounted at the apex of the lift cell. The bottom drive
assembly is mounted at the base of the lift cell and is described as an assembly with an electrical motor, a
drive pulley, and an idler pulley. The top drive assembly is linked to the bottom drive assembly by a belt,
which attaches to the carriage.
The carriage is an assembly that moves vertically within the lift cell and contains both spring-loaded wheels
and pivoting wheels that align with the guide rails. The LHD assembly is mounted to the carriage, and is
described as a horizontal platform for open or closed cartons, shrink-wrapped trays, plastic totes, etc.
The applicable subheading for the Mastless Lift Cell will be 8428.10.0000, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for “Other lifting, handling, loading or unloading machinery (for
example, elevators, escalators, conveyors, teleferics): Passenger or freight elevators other than continuous
action; skip hoists.” The general rate of duty will be free.
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 the European
Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15
percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General
duty rate. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e., 9903.02.20, in addition to subheading 8428.10.0000, HTSUS, listed above.
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 system 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 Paul Huang at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division