CLA-2-87:OT:RR:NC:N2:201
Karam Salih
Autophox LLC
1923 Highway 6 S
Houston, TX 77077
RE: The tariff classification of electric vehicles from China
Dear Mr. Salih:
In your letter dated February 11, 2026, you requested a tariff classification ruling.
The item under consideration has been identified as a fully assembled, four-wheeled, battery-electric,
permanently enclosed low-speed personnel carrier intended for private property security patrol use (e.g.,
campuses and similar controlled premises), designed to transport a single security officer, which you have
identified as model “E3-S”. You state that it is intended to replace open-air golf carts commonly used by
security patrol officers. You state that the vehicle has the following dimensions, 6.6ft L x 3ft W x 5.2ft H.
The vehicle has one forward-facing seat with seat belt, an enclosed body with automotive-style doors, and
standard vehicle lighting (headlamps/taillamps/turn signals) for safe night use, and mirrors for visibility. It is
additionally equipped with roof-mounted security strobe lights, which were not pictured in the sample
photos. You state that the vehicle is not designed or marketed to transport cargo and has no cargo bed or
cargo box.
Propulsion is provided solely by an electric motor rated at 3 kW powered by a 60V 150Ah lithium battery
system. The vehicle’s maximum speed is mechanically limited by gearing to 19 miles-per-hour (mph) and it
bears a 10-digit manufacturer serial number. The importer’s intended end use is operation strictly on private
property rather than public-road use. You state the vehicle is capable of traveling approximately 60 miles per
charge.
The applicable subheading for the E3-S will be 8703.90.0100, Harmonized Tariff Schedule of the United
States (HTSUS), which provides for “Motor cars and other motor vehicles principally designed for the
transport of persons (other than those of heading 8702), including station wagons and racing cars: Other.”
The general rate of duty will be 2.5% 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
(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 Matthew Sullivan at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division