CLA-2-85:OT:RR:NC:CEE008:N4:410
Bruce Ashton
Dyson Technology Ltd.
Tetbury Hill, Malmesbury SN16 0RP
Malmesbury SN16 0RP
United Kingdom
RE: The tariff classification of a robot vacuum cleaner featuring mopping, self-cleaning and self-dry
function from China
Dear Mr. Ashton:
In your letter dated December 8, 2025, you requested a tariff classification ruling. Pictures and product
specifications were submitted with your request.
The product is a vacuum cleaner identified as “Dyson Spot+scrub Ai”, which is also referred to as RB05.
Your submission literature indicates that the RB05 is a round-shaped wet and dry-cleaning robot vacuum
featuring mopping, self-cleaning and self-dry function utilizing a docking station. The vacuum cleaner
self-contains an electric motor with a dust bag less than 20 liters and is rated not exceeding 1,500W.
Specifically, you describe the product details as follows:
The robot vacuum cleaner is multi-function electromechanical domestic appliance, which is designed to spot,
scrub, mop and vacuum with a self-cleaning function. Spot+ Scrub AI is in a circular shape measuring
approximately 370mm in length, 373mm in width and 8110mm in height, and has a dust collection bin
capacity of 250ml. It also comes with clean water tank capacity of 300 ml and dirt tank capacity of 180 ml.
This model is rated 60W.
The appliance is powered by two traction wheels at the side and a front wheel. The dust and other materials
are collected in an internal dust bag/receptacle, whereas the air is suctioned in and filtered by an HEPA (H13)
filter. After the floor cleaning task is completed, the robot will return to the self-cleaning dock to initiate the
self-cleaning procedure. The dock is designed to collect dust and debris from the vacuum cleaner, empty the
dirty water, refill clean water tank, clean mopping pads with hot water, dry mopping pads and as well as
charge the robot.
The robot vacuum cleaner is supported by 5000mAh Li-ion battery, and it’s equipped with Lidar, Gyroscope,
visual camera and sensors for level detections, position detections, obstacle detection, carpet detection, wall
detection, fall prevention detection, laser obstacle detection, dust/dirt detection, etc.
The docking station measures approximately 400mm in length, 502mm in depth and 471mm in height. The
docking station comes with a tank capacity of 2.5L for clean water and 2.5L for dirty water. This station can
dry the mop with hot air blower and quicker dry. The station supports automatic water filling and contains a
320ml tank for adding cleaning solution.
This docking station connects directly to the wall socket with plug and play power cord. The entire product is
connected to an App which controls various functions of the machine as listed below: area cleaning, fixed
point cleaning, border cleaning, schedule cleaning, air suction adjustment, water volume regulation, map
memory, 3D map, automatic lifting of carpet/mop, automatic pressure increase for carpet cleaning, option to
do only mop and only vacuum.
In your letter, you proposed that the correct classification of the “Dyson Spot+scrub Ai” should be
subheading 8509.80.5095, Harmonized Tariff Schedule of the United States (HTSUS), which provides for
electromechanical domestic appliances, with self-contained electric motor, other than vacuum cleaners of
heading 8508, parts thereof: other appliances: other: other.
We disagree.
The “Dyson Spot+scrub Ai” is a vacuum cleaner with features of mopping, self-cleaning and self-dry
function utilizing a docking station. Heading 8509 excludes vacuum cleaners of heading 8508. As such,
classification in heading 8509 is inappropriate.
The applicable subheading for the “Dyson Spot+scrub Ai” will be 8508.11.0000, HTSUS, which provides for
“Vacuum cleaners, parts thereof: With a self-contained electric motor: Of a power not exceeding 1,500 W
and having a dust bag or other receptacle capacity not exceeding 20 l”. The rate of duty will be Free.
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 CBP Regulations (19 CFR 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 Michael Chen at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division