CLA-2-84:OT:RR:NC:N1-104
Peter Lee
Faraday Future
18455 South Figueroa Street
Gardena, CA 90248
RE: The tariff classification of robotic platforms from China
Dear Mr. Lee:
In your letter dated November 17, 2025, you requested a tariff classification ruling.
The merchandise in question consists of four robotic platforms manufactured by AgiBot in China. The robots
are programmable, embodied-intelligence robotic systems incorporating mechanical actuators, control
processors, sensors, and AI-based software enabling autonomous or semi-autonomous operation.
AgiBot A2 Ultra is a full-size humanoid robot approximately measuring 169 cm tall and weighing 69 kg,
with 40 degrees of freedom. It features bipedal locomotion, articulated limbs, speech and vision-based
interaction, and operates untethered using rechargeable lithium batteries. As imported, it will include a robot
body, onboard computing, depth cameras, LiDAR, IMU, torque sensors, battery pack, battery charger,
accessory charger, microphone, and a remote controller.
AgiBot X2 Ultra is mid-size humanoid research robot approximately 130 cm tall and weighing 35 kg. As
imported, it will includes a robot body, a battery charger, accessory charger, microphone, battery charger,
accessory charger, and a remote controller.
AgiBot D1 Ultra is a quadruped (robot dog) robotic platform measuring approximately 630 × 360 × 415 mm.
This robot supports an 8–10 kg payload, carries sealed electronics rated to IP54, and reaches speeds up to 3.7
m/s. It uses electric servo actuation, dynamic stabilization, and onboard navigation to traverse uneven terrain.
As imported, it will include a robot body, battery pack, battery charger, and a remote controller.
AgiBot D1 Edu is a smaller quadruped robot measuring approximately 680 × 370 × 406 mm and weighing
about 15 kg. It shares core mechanics with the D1 Ultra but is simplified for academic/educational
instruction. As imported, it will include a development kit and simulation tools for STEM and AI training. It
includes a robot body, battery pack, battery charger, and a remote controller.
All four robots are imported with embedded firmware and core control software. Regarding the software, the
robots run (1) embedded real-time/motion-control software (actuator control, gait, balance, safety); (2)
perception & navigation software (camera/LiDAR processing, where equipped); and (3) human-interaction
software (voice/mic, vision-based recognition, scripted behaviors). This software is stored on-board in the
robot’s internal computing/control system. All the robots can be programmed and customized for the user’s
needs, supporting configuration and/or secondary development. The robots perform embedded onboard data
processing only as required to operate as robots: sensor processing (vision/LiDAR where applicable), motion
control, navigation, interaction logic, and safety monitoring.
In your submission you state that the robots will not be used by Faraday Future for commercial purposes.
Rather, you indicate that the company will only use these robots for demonstration, presentation, reception
and tour-guide scenarios for visiting guests and partners, helping explain vehicle concepts and technologies
in an engaging and interactive manner, as well as illustrating robotics, AI, and motion-control principles.
While you did not suggest a particular tariff heading, we note that heading 9023, Harmonized Tariff Schedule
of the United States (HTSUS), in part provides for “Instruments, apparatus and models, designed for
demonstrational purposes (for example, in education or exhibitions), unsuitable for other uses, . . ..”
However, for the following reasons, heading 9023 is inapplicable to the subject robots.
In your submission, you acknowledged that the robots are not designed or engineered specifically or solely
for demonstrational use, and are in fact designed to function as commercial products that can be programmed
to perform various tasks beyond demonstration. For example, the A2 Ultra humanoid robot can walk and
grasp and move or deliver items. It also features autonomous route planning and intelligent obstacle
avoidance. The A2 Ultra is also capable of person and object recognition, bilingual conversation, and for
performing guided tours. Like the A2, the X2 humanoid robot supports facial recognition, object detection,
gesture recognition, and environmental semantics. The X2 has touch sensor interaction and can grasp and
move or deliver objects. The D1 Ultra quadruped robot is designed for payload and application mounting and
can navigate complex terrain while moving quickly. The D1 Ultra can be used in commercial, industrial, and
specialized field environments including emergency, security, inspection, and inspection fields, in addition to
research, education, and entertainment. While the D1 Edu quadruped lacks some of the D1 Ultra’s
capabilities, it is still capable of functions beyond mere demonstrations; it is compatible with a wide range of
modules and payload integration and is designed for training and entry-level scientific research as well as
entertainment performances.
Because these robots are not specially designed for demonstration purposes and are suitable for uses beyond
demonstration, they cannot be classifiable in heading 9023, HTSUS. Rather, the four robots have functional
capabilities, applications, and uses that are not limited to demonstration or presentation, e.g., service,
inspection, research, and other specialty fields.
The applicable subheading for all four AgiBot robotic platforms, A2 Ultra, X2 Ultra, D1 Ultra, and D1 Edu,
will be 8479.89.9599, HTSUS, covering “Machines and mechanical appliances having individual functions,
not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances:
Other: Other: Other.” The general rate of duty will be 2.5 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 subheading 8479.89.9599, HTSUS, listed above.
On March 12, 2025, Presidential Proclamation 10895 imposed additional tariffs on certain derivative
aluminum products. Additional duties for derivative aluminum products of 50 percent are reflected in
Chapter 99, headings 9903.85.04, 9903.85.07, and 9903.85.08. Products provided by heading 9903.85.08, as
well as products of Chapter 76 provided by 9903.85.04 and 9903.85.07, will be subject to a duty of 50
percent upon the value of the aluminum content. At the time of entry, you must report the Chapter 99 heading
applicable to your product classification, i.e. 9903.85.08, in addition to subheading 8479.89.9599, HTSUS.
Derivative aluminum articles processed in another country from aluminum articles that were smelted and cast
in the United States, provided for in heading 9903.85.09, 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 9903.85.09 this additional duty applies to the non-aluminum 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 subheading 8479.89.9599, HTSUS, listed above.
Products of China classified under subheading 8479.89.9599, HTSUS, unless specifically excluded, are
subject to the 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 8479.89.9599, 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 Arthur Purcell at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division