CLA-2-85:OT:RR:NC:N2 207
Robert Scott
Curtiss-Wright Controls Integrated Sensing, Inc.
1100 W Grove Pkwy, Ste 102
Tempe, AZ 85283
RE: The tariff classification of components for motors and sensors from various countries
Dear Mr. Scott:
In your letter dated March 22, 2026, you requested a tariff classification ruling.
There are three items at issue with this request, which are all identified as components for motors or sensors
incorporated into a thermal management system within an aircraft. Each item is identified by part numbers
H448B Motor/RVDT/Gearhead, 1075-608-016 RVDT Core Assembly, and 1140-608-016 Secondary Core.
The H448B Motor/RVDT/Gearhead is comprised of a stepper motor, rotary variable differential transformer
(RVDT), and gearhead. The stepper motor is a DC type brushless motor with a maximum power output of 38
Watts. The RVDT is a rotary position sensor and the gearhead is incorporated to modify the speed/torque of
the motor. The component uses electromagnetic principles to convert electrical power into mechanical power,
which is transferred through the mechanical gear transmission to the output of the rotary actuator to interface
with the butterfly valve in an aircraft’s thermal management system. You state that this component originates
from Mexico.
The 1075-608-016 RVDT Core Assembly is a part of the RVDT position feedback sensor for the correct
operation of the aircraft system valves. It is the stator for the RVDT position transducer. An electromagnetic
field is created in the excitation windings and measured in the differential windings as a function of the rotor
position. You state that this component originates from Costa Rica.
The 1140-608-016 Secondary Core is a machined part of a core assembly of an RVDT rotary position sensor.
It is used to enable position measurement by carrying the electromagnetic flux created by the excitation
windings to the differential windings, allowing the voltage differential to be measured and infer precise
position. You state that this component originates from Canada.
In your request, you suggest that the H448B Motor/RVDT/Gearhead is correctly classified under subheading
8501.31.2000, Harmonized Tariff Schedule of the United States (HTSUS). You further suggest that
1075-608-016 RVDT Core Assembly and 1140-608-016 Secondary Core are correctly classified under
subheading 8543.90.8885, HTSUS. We agree.
The applicable subheading for the H448B Motor/RVDT/Gearhead will be 8501.31.2000, HTSUS, which
provides for “Electric motors…: Other DC motors; DC generators: Of an output not exceeding 750 W:
Motors: Exceeding 37.5 W but not exceeding 74.6 W”. The general rate of duty will be 2.8 percent ad
valorem.
The applicable subheading for the 1075-608-016 RVDT Core Assembly and 1140-608-016 Secondary Core
will be 8543.90.8885, HTSUS, which provides for “Electrical machines and apparatus, having individual
functions, not specified or included elsewhere in this chapter; parts thereof: Parts: Other: Other: Other:
Other.”. 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/.
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 P. Forkan
Director
National Commodity Specialist Division