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