CLA-2-84:OT:RR:NC:N1:103

Christopher Ridgway
Miba Group
5045 N State 60 NW
Mcconnelsville, OH 43756

RE: The tariff classification of a portal robot handling unit from Austria

Dear Mr. Ridgway:

In your letter dated March 17, 2026, you requested a tariff classification ruling.

The merchandise under consideration is identified as the Miba Cube US 810D and is described as a portal robot handling unit for loading and unloading workpieces up to 200 millimeters in diameter. The workpieces are loaded and unloaded from containers called cubes, which are transported through the unit by conveyors.

The system consists of an enclosure that measures approximately 3.12 meters in length, 1.48 meters in width, and 2.64 meters in height. Inside the enclosure are a clamping module, a Z1-axis module, a space gantry module, and a gripper interface module. The Z1-axis module uses forks to lift a stack of cubes, which are held in place by the clamping module. The clamping module separates and releases one cube layer at a time, after which the Z1-axis module lowers it to the working position for the space gantry module. The space gantry module operates as a three-axis cartesian coordinate system and positions the gripper module, which removes or places workpieces into each cube.

The conveyor system is not included at the time of importation and will be incorporated into the Miba Cube in the United States.

In your submission, you suggest that the Miba Cube is classifiable under subheading 8428.70.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other lifting, handling, loading or unloading machinery (for example, elevators, escalators, conveyors, teleferics): Industrial robots.” While we agree that the product is classified in heading 8428, we disagree with the suggested subheading. The Miba Cube is not merely an industrial robot, but a complete system with multiple assemblies. Specifically, it includes a lifting/lowering unit, a clamping system, and a gripper module, which collectively contribute to the function of loading and unloading workpieces. The applicable subheading for the Miba Cube US 810D will be 8428.90.0390, HTSUS, which provides for “Other lifting, handling, loading or unloading machinery (for example, elevators, escalators, conveyors, teleferics): Other machinery: Other.” The general rate of duty will be free.

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 P. Forkan
Director
National Commodity Specialist Division