CLA-2-73:OT:RR:NC:N1:164
David Robeson
Mohawk Global Trade Advisors
123 Air Cargo Road
North Syracuse, NY 13212
RE: The tariff classification of an empty electrical junction box from China
Dear Mr. Robeson:
In your letter dated December 26, 2025, you requested a tariff classification ruling on behalf of your client,
Altronic. Technical information was submitted with your request.
The item under consideration is an empty electrical junction box (Part Number 710121) for the Altronic
CPU-95 digital ignition system for a spark-ignited, natural gas-fueled industrial engine. You state that the
14-gauge steel junction box protects the unit’s electronic components from dirt, dust, and other
environmental conditions. To minimize cable length and signal loss, the box in question is usually mounted
on the machinery itself or on a nearby wall.
As described, the junction box features attachment points on its four corners for mounting with bolts, a
removable gland plate, a swinging door with two steel latch clips, and two circular cutouts on each side for
connections to the engine and display module/control unit. The junction box measures 9.9 inches in length by
9.75 inches in width by 6.25 inches in height. In your letter, you assert that the junction box is custom-fitted
for use with the CPU-95 ignition unit and has no alternative use. At importation, the junction box will be
empty with no electronic components included.
You propose classification in subheading 8511.90.2000, Harmonized Tariff Schedule of the United States
(HTSUS), which provides for “Electrical ignition or starting equipment of a kind used for spark-ignition or
compression-ignition internal combustion engines (for example, ignition magnetos, magneto-dynamos,
ignition coils, spark plugs and glow plugs, starter motors); generators (for example, dynamos, alternators)
and cut-outs of a kind used in conjunction with such engines; parts thereof.” We disagree. As you describe,
the junction box will be empty at the time of importation and will have no electronic components included.
As such, the junction box is not identifiable as being used with the electrical ignition equipment of heading
8511. Consequently, classification as a “part” covered by heading 8511, HTSUS, is precluded.
Alternatively, you propose classification in subheading 9403.20.0090, HTSUS, which provides for “Other
furniture and parts thereof: Other metal furniture: Other: Other.” Based on the submitted information, the
junction box is not an article of furniture and is more specifically provided for elsewhere in the tariff. As a
result, classification in heading 9403, HTSUS, is precluded.
Heading 7326, HTSUS, is a residual or basket provision which covers a wide range of iron or steel articles
that are not more specifically provided for elsewhere in the HTSUS. The Explanatory Notes (ENs) to heading
7326 state that “This heading covers all iron or steel articles obtained by forging or punching, by cutting or
stamping or by other processes such as folding, assembling, welding, turning, milling or perforating other
than articles included in the preceding headings of this Chapter or covered by Note 1 to Section XV or
included in Chapter 82 or 83 or more specifically covered elsewhere in the Nomenclature.” An article of iron
or steel can be classified in heading 7326 if it is determined that the item is not more specifically provided for
in any other heading of the tariff. As described in this submission, the empty electrical junction box is not
specifically covered elsewhere in the tariff. Accordingly, it is classifiable in heading 7326, HTSUS.
The applicable subheading for the empty electrical junction box will be 7326.90.8688, HTSUS, which
provides for “Other articles of iron or steel: Other: Other: Other: Other: Other.” The general rate of duty will
be 2.9 percent ad valorem.
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
(C.F.R.), 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 C.F.R. 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 Paul Taylor at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division