CLA-2-90:OT:RR:NC:N1:105
Jonathan Wise
Keysight Technologies, Inc.
1400 Fountaingrove Parkway
Santa Rosa, CA 95403
RE: The tariff classification of a regenerative emulator from Malaysia
Dear Mr. Wise:
In your letter dated February 11, 2026, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The item under consideration is described as the SL1200A Series Regenerative 3Phase AC Emulator, which
is a high-power, bidirectional grid simulation system designed specifically for testing electric vehicle
charging infrastructure (EVSE), electric vehicle (EV) onboard chargers, and grid-edge applications like solar
photovoltaic (PV) inverters and energy storage systems. It provides comprehensive testing capabilities up to
1200 volts alternating current (VAC) and power levels ranging from 30 kW to 810 kW (up to 1.08
mega-volt-ampere (MVA) when paralleled) without requiring an external transformer. As a 100%
regenerative and bidirectional system with over 85% efficiency, it enables energy-saving, four-quadrant
power operation, making it ideal for simulating real-world grid conditions, including harmonic injection and
high-voltage ride-through (HVRT) tests. The system features power outputs from 42 kVA to 135 kVA and
voltage ranges of 600 VAC and 1200 VAC. The system allows for dual-ranges that allow for both low and
high-voltage testing in the same footprint. The series is controlled via an intuitive Soft Front Panel (SFP) and
supports automation of complex grid compliance standards such as IEEE 1547 and UL 1741 SB.
The SL1200A AC emulator measures voltage and current during testing by simulating AC power conditions
and analyzing how a device under test behaves in response. The emulator monitors the voltage levels
provided to the device being tested, ensuring that the desired output matches the set values. It can simulate
various voltage conditions, like fluctuations, to test the device’s performance and stability. The emulator also
measures the current drawn by the device, helping assess its efficiency and power consumption. It can
analyze how the device reacts to changes in current, such as spikes or variations in load. The SL1200A AC
emulator does not include a recording device or internal memory and therefore cannot store measurement
results internally. Instead, all measurement data is stored externally in the memory of the connected
computer.
As you suggest in your letter, the applicable subheading for the SL1200A Series Regenerative 3Phase AC
Emulator will be 9030.33.3800, Harmonized Tariff Schedule of the United States (HTSUS), which provides
for “Oscilloscopes, spectrum analyzers and other instruments and apparatus for measuring or checking
electrical quantities, excluding meters of heading 9028; instruments and apparatus for measuring or detecting
alpha, beta, gamma, X-ray, cosmic or other ionizing radiations; parts and accessories thereof: Other
instruments and apparatus, for measuring or checking voltage, current, resistance or power (other than those
for measuring or checking semiconductor wafers or devices): Other, without a recording device: Other.” The
general 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 the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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 Jason Christie at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division