CLA-2-85:OT:RR:NC:N2:212
James Rogers
Nelson Mullins Riley & Scarborough, LLP
2 W Washington Street, Suite 400
Greenville, SC 29601
RE: The tariff classification of busbars from Germany
Dear Mr. Rogers:
In your letter dated November 13, 2025, you requested a tariff classification ruling on behalf of your client,
Gindre Copper, Inc.
The merchandise under consideration is identified as the MaxiFlex Flexible Insulated Busbar. The subject
busbar is comprised of stacked copper plates cut to a specific length and laminated with thermoplastic
insulation. The busbars are imported in straight form as well as bent to the customer’s specifications.
However, in both forms the bars do not have any connection points. In use, the busbars are used within
high-current electrical power distribution systems such as switchgear, electrical vehicle charging equipment,
and other power cabinets. The busbars function as conductors of electricity within these systems and are rated
for a voltage exceeding 1,000 V.
In your request, you suggest that the correct classification for the subject devices should be 8544.60.4000,
Harmonized Tariff Schedule of the United States (HTSUS). We agree.
The applicable subheading for the MaxiFlex Flexible Insulated Busbar will be 8544.60.4000, 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: Other: Of Copper.” The general rate of duty will
be 3.5% 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 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 or exclusion subheading, in addition to subheading 8544.60.4000, 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