CLA-2-87:OT:RR:NC:N2:201
Jerome Owens
I-Logix Customs, Inc.
780 South Nogales Street, Suite E
City of Industry, CA 91748
RE: The tariff classification of an electric vehicle from China
Dear Mr. Owens:
In your letter dated March 2, 2026, you requested a tariff classification ruling on behalf of your client, JDT
Cars & Electric Cars, Inc., located in Downy, CA.
The item under consideration has been identified as a replica Volkswagen (VW) Van, designed to resemble
the iconic “VW Microbus” of the 1960s and 1970s. The vehicle is custom built in China and can be equipped
with either a “traditional” internal combustion engine, or electric motors to create a fully electric vehicle.
You state that after customization the vehicle is shipped to the U.S. to serve as a mobile food cart at facilities
like Disneyland, hotels, and the like.
You state the instant shipment, involves a VW replica equipped with electric motors, the capacity of which
can vary and ultimately depends on the buyer's preference. You state that this specific vehicle will have a
4KW electric motor, which equates to about 5 to 10 miles per hour.
While you claim that these models are mostly made permanent fixtures at the various location, they do
possess the ability to be moved within the lots, parameters, etc.
In your request you suggest classification in 8704.60.0000, Harmonized Tariff Schedule of the United States
(HTSUS), which provides for motor vehicles for the conveyance of cargo. We concur.
The applicable subheading for the electric powered replica Volkswagen Van will be 8704.60.0000, HTSUS,
which provides for “Motor vehicles for the transport of goods: Other, with only electric motor for
propulsion.” The general rate of duty will be 25% ad valorem.
Importations of this product may be subject to the provisions of Section 133 of the Customs Regulations if
they copy or simulate a registered trademark, trade name or copyright recorded with U.S. Customs and
Border Protection. If you are an authorized importer of the product we recommend notifying your local
Customs office prior to importation.
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 Matthew Sullivan at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division