CLA-2-84:OT:RR:NC:N1:102
Paul Wright
Legacy Electric Motors, LLC
2800 NW 91st Street
Vancouver, WA 98665
RE: The tariff classification of pump assemblies from Japan
Dear Mr. Wright:
In your letter dated November 18, 2025, you requested a tariff classification ruling. Descriptive information
was provided with your submission
The products under consideration are the EMQY, EMQ, EMJY and EMK series pump assemblies. The
assemblies, which are primarily of cast iron, consist of a casing that houses an impeller coupled to an electric
motor. In use, the assemblies are submerged, and slurry, slug or other liquids are pumped and discharged
through the pump’s wet end, which is imported separately. The wet end consists of the casing and casing
liner, a backplate, and sealing components such as gasket material and a mechanical seal. The pump
assemblies are designed to be used in various applications such as water plants, mining operations, steel mills
and dredges.
As the pump assemblies will be imported incomplete, you suggest the assemblies should be classified within
subheading 8413.91, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Pumps
for liquids, whether or not fitted with a measuring device; liquid elevators; part thereof: Parts. We disagree.
Classification of merchandise under the HTSUS is governed in accordance with the General Rules of
Interpretation (GRIs). 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 GRIs taken in order.
In following the sequence of the GRIs, GRI 2(a) provides that 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, which are entered unassembled or disassembled.
At the time of importation, the products will have the essential character of complete pump assembles
classified within heading 8413. As such, the applicable subheading for the EMQY, EMQ, EMJY and EMK
series pump assemblies will be 8413.70.2004, HTSUS, which provides for Pumps for liquids, whether or not
fitted with a measuring device; liquid elevators; part thereof: Other centrifugal pumps: Other: Submersible
pumps. The general rate of duty will be Free.
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/.
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 Sandra Martinez at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division