CLA-2-87:OT:RR:NC:N2 206
Claire Brisiel
Assembled Products Corporation
405 W. Easy Street
Rogers, AR 72756
RE: The tariff classification of wheel hub motors for shopping carts from China
Dear Ms. Brisiel:
In your letter dated November 7, 2025, you requested a tariff classification ruling.
The merchandise under consideration is described as three different models of Martcart Hub Motors, which
are identified by part numbers 280-0177, 280-0264, and 280-0071. They are wheel hub motors designed to be
installed in motorized shopping carts for individuals with limited mobility. The wheels have electric motors
housed inside the hub of the wheel, which will power the wheel itself to move the shopping cart. We note
that the motorized shopping cart is not part of this ruling request.
In your submission, you suggest that the subject items are correctly classified under subheading
8714.20.0000, Harmonized Tariff Schedule of the United States (HTSUS) as “Parts and accessories of
headings 8711 to 8713: Of carriages for disabled persons.” We disagree.
The subject wheels are designed to fit a motorized shopping cart that is intended to be used only in retail
settings. The shopping cart is designed for use by any person in the retail store with limited mobility, not
solely for individuals with chronic or permanent disabilities. Furthermore, the shopping cart is equipped with
a shopping basket primarily designed to carry items in the retail store and it is not dedicated to the carriage of
disabled person. Therefore, the classification of the wheel hub motors under subheading 8714.20.0000,
HTSUS, is inappropriate.
The General Rules of Interpretation (GRIs) of the HTSUS, when taken in numerical order, set forth the
official guidance for classifying merchandise as it enters the United States. GRI 1 states, in part, that for legal
purposes, classification shall be determined according to the terms of the headings, any relative section or
chapter notes and, unless otherwise required, according to the remaining GRI’s taken in order. Goods that
are, prima facie, classifiable under two or more headings, are classifiable in accordance with GRI 3, HTSUS.
GRI 3(a) states, in part, when two or more headings each refer to part only of the materials or substances
contained in mixed or composite goods, those headings are to be regarded as equally specific, even if one
heading gives a more precise description of the good. Goods classifiable under GRI 3(b) are classified as if
they consisted of the material or component which gives them their essential character, which may be
determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a
constituent material in relation to the use of the article. GRI 3(c) provides that when goods cannot be
classified by reference to GRI 3(a) or 3(b), they are to be classified in the heading that occurs last in
numerical order among those which equally merit consideration.
In our view, the subject wheel hub motors meet the definition of composite good as it contains both the wheel
and electric motor as propulsion for the shopping cart. Further, it is our opinion that neither of these
components impart the essential character of the finished item as both are critical to the expected end use.
After a review of the competing subheadings, we have determined that the wheels occur last in numerical
order.
The applicable subheading for the Martcart Hub Motor, part numbers 280-0177, 280-0264, and 280-0071,
will be 8708.70.6060, HTSUS, which provides for “Parts and accessories to the motor vehicles of headings
8701 to 8705: Road wheels and parts and accessories thereof: For other vehicles: Parts and Accessories:
Other.” The general rate of duty will be 2.5% 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 subheading 8708.70.6060, 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 China, Hong
Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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 subheading 8708.70.6060, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8708.70.6060, 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 8708.70.6060, 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.
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 Liana Alvarez at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division