CLA-2-85:OT:RR:NC:N1:103
Paul Biegen
Our Next Energy, Inc.
45145 West 12 Mile Road
Novi, MI 48377
RE: The tariff classification of an enclosure weldment from China
Dear Mr. Biegen:
In your letter dated March 16, 2026, you requested a tariff classification ruling.
The merchandise under consideration is referred to as a bent enclosure weldment, part number 100074388,
which serves as a structural enclosure for an electric battery pack. The weldment is made from steel sheet
metal and is open on three sides (front, rear, and top). It is designed for a specialized 72 VDC auxiliary
battery pack used in DC energy storage applications for rail systems. Typical applications include engine
start support and powering hotel loads (e.g., non-propulsion electrical loads such as lighting, HVAC, etc.) on
locomotives.
In the United States, lithium iron phosphate battery cells and a battery management system are mounted in
the enclosure, which is then sealed by a rear plate, a lid, and a front plate assembly.
The applicable subheading for the bent enclosure weldment, part number 100074388, will be 8507.90.8000,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric storage batteries,
including separators therefor, whether or not rectangular (including square); parts thereof: Parts: Other.” The
general rate of duty will be 3.4 percent ad valorem.
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 Paul Huang at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division