CLA-2-85:OT:RR:NC:N2 207
John Morello
Freesuns SA
Chemin De La Severire 6, Vaud
Colombier VD 1114
Switzerland
RE: The tariff classification of solar roof tiles from China
Dear Mr. Morello:
In your letter dated February 24, 2026, you requested a tariff classification ruling.
The merchandise under consideration is described as the Freesuns Solar Roof Tile identified by model name
Solaris Heritage. The solar roof tile mimics slate roof tiles in appearance but generates electricity using the
solar cells within the tile, while also providing weather protection for the roofs of commercial and residential
buildings. The solar roof tile measures 28 x 20 inches which contains 7 half cut standard monocrystalline
photovoltaic solar cells laminated between two layers of tempered glass. The tile also features a junction box
with two cables affixed with MC4 connectors and a bypass diode. We note that the subject tiles are not
imported with inverters, optimizers, or any similar power managing components.
In your request, you suggest that the correct classification for the solar roof tile is under subheading
8541.43.0010, Harmonized Tariff Schedule of the United States (HTSUS). We agree.
The applicable subheading for the Freesuns Solar Roof Tile, model name Solaris Heritage, will be
8541.43.0010, HTSUS, which provides for “Semiconductor devices (for example, diodes, transistors,
semiconductor-based transducers); photosensitive semiconductor devices, including photovoltaic cells
whether or not assembled in modules or made up into panels;…Photosensitive semiconductor devices,
including photovoltaic cells whether or not assembled in modules or made up into panels; light-emitting
diodes (LED): Photovoltaic cells assembled in modules or made up into panels: Crystalline silicon
photovoltaic cells of a kind described in statistical note 12 to this chapter.” 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/.
Please note that this product may be subject to antidumping duties or countervailing duties (AD/CVD). When
there is a question as to whether merchandise is subject to an antidumping or countervailing duty order or
considered to be defined by the scope of an order, such a determination is governed by the U.S. Department
of Commerce’s International Trade Administration (“Commerce”). Commerce issues scope rulings to
determine whether merchandise which is in commercial production is covered by the scope of an
antidumping or countervailing duty order. Commerce’s scope rulings are separate and distinct from decisions
issued by CBP regarding tariff classification and country of origin for purposes such as duty assessment and
marking.
To seek a scope ruling, please visit the website of Commerce’s International Trade Administration. A guide
to seeking a scope ruling can be found at
https://access.trade.gov/help/Scope_Ruling_Guidance_(4.1.2022).pdf. A list of current AD/CVD
investigations at the United States International Trade Commission can be viewed on its website at
http://www.usitc.gov. Additionally, messages sent by Commerce to CBP regarding AD/CVD cash deposits
and liquidation can be searched using ACE or CBP’s search tool at
https://trade.cbp.dhs.gov/ace/adcvd/adcvd-public/#.
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 Howard Suh at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division