CLA-2:OT:RR:NC:N2:209
Ian Widman
Cassidy Levy Kent (USA) LLP
2112 Pennsylvania Avenue NW, Suite 300
Washington, DC 20037
RE: The tariff classification of stator and rotor pairs from Mexico
Dear Mr. Widman:
In your letter dated November 18, 2025, you requested a tariff classification ruling on behalf of your client
Whirlpool Corporation.
The merchandise under consideration is identified as unassembled electric motors, referred to as “stator and
rotor pairs”, for food waste disposers, SKU numbers 81202, 81202B, 81202N, 81202P, and 16295B. The
stators and rotors are separately packed and imported on the same shipment to the United States for assembly
into a functional electric motor. In Mexico, the stators are produced from steel that is stamped into
laminations and stacked. Slot liners are then inserted, and windings are wrapped around the core. The
windings are then secured with polyester lacing to prevent movement, and lead wires are attached to the
windings. The rotors are produced from steel that is stamped into laminations and cast with aluminum. The
stators and rotors are separately packed and imported on the same shipment to the United States for assembly
into a functional electric motor for a food waste disposer.
The electric motor, Whirlpool Corporation SKU number 81202 is a single-phase AC motor, without gears,
with a maximum output capacity of 298.28 W. SKU number 81202B is a single-phase AC motor, without
gears, with a maximum output capacity of 391.49W. SKU number 81202N is a single-phase AC motor,
without gears, with a maximum output capacity of 745.7 W. SKU number 81202P is a single-phase AC
motor, without gears, with a maximum output capacity of 932.12 W. Lastly SKU number 16295B is a
multi-phase AC motor, without gears, with a maximum output capacity of 2237 W.
You suggest heading 8501.40.4040, Harmonized Tariff Schedule of the United States (HTSUS) for SKU
numbers 81202 and 81202B, heading 8501.40.5040, HTSUS, for SKU number 81202N, heading
8501.40.6040, HTSUS, for SKU number 81202P, and heading 8501.52.4000, HTSUS, for SKU number
16295B. You also suggest General Rule of Interpretation (GRI) 2 (a) as a basis for classifying these devices
as a complete motor. GRI 2 (a) states, “Any reference in a heading to an article shall be taken to include a
reference to that article incomplete or unfinished, provided that, as entered, the incomplete or unfinished
article has the essential character of the complete or finished article. It shall also include a reference to that
article complete or finished (or falling to be classified as complete or finished by virtue of this rule), entered
unassembled or disassembled.” This office agrees that the rotor and stator are considered the essential
character of the finished electric motor.
The applicable subheading for the stator and rotor pairs for an unassembled electric motor, Whirlpool
Corporation SKU 81202 and 81202B will be 8501.40.4040, Harmonized Tariff Schedule of the United States
(HTSUS), which provides for Electric motors and generators (excluding generating sets): Other AC motors,
single-phase: Of an output exceeding 74.6 W but not exceeding 735W. The general rate of duty will be 4
percent.
The applicable subheading for the stator and rotor pairs for an unassembled electric motor, Whirlpool
Corporation SKU 81202N will be 8501.40.5040, Harmonized Tariff Schedule of the United States (HTSUS),
which provides for Electric motors and generators (excluding generating sets): Other AC motors,
single-phase: Of an output exceeding 735 W but not under 746W. The general rate of duty will be 3.3
percent.
The applicable subheading for the stator and rotor pairs for an unassembled electric motor, Whirlpool
Corporation SKU 81202P will be 8501.40.6040, Harmonized Tariff Schedule of the United States (HTSUS),
which provides for Electric motors and generators (excluding generating sets): Other AC motors,
single-phase: Other: Other. The general rate of duty will be 3.7 percent.
The applicable subheading for the stator and rotor pairs for an unassembled electric motor, Whirlpool
Corporation SKU 16295B will be 8501.52.4000, Harmonized Tariff Schedule of the United States (HTSUS),
which provides for Electric motors and generators (excluding generating sets): Other AC motors,
multi-phase: Of an output exceeding 750W but not exceeding 75kW: Exceeding 750 W but not exceeding
14.92kW. The general rate of duty will be 3.7 percent.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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 Steven Pollichino at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division