CLA-2-85:OT:RR:NC:N2:220
Kyung-jin Moon
JINSOL Customs Consulting & Logistic Service
129, Gaetbeol-ro
Yeonsu-gu, Incheon 21999
South Korea
RE: The tariff classification of side mount electrical conductor assemblies from Korea
Dear Moon Kyung-jin:
In your letter dated April 3, 2026, you requested a tariff classification ruling.
There are two items under consideration with this request. Both are side mount electrical conductor
assemblies identified by item numbers 1974315-00 and 1974314-00. The primary difference between the two
items is that one is used on the positive side of an electric vehicle battery module and the other is used on the
negative side. Both items are generally manufactured of the same components with slight variations in the
size, shape, and connector configurations. Both items consist of an aluminum electrical conductor bar. The
electrical conductor bar is enclosed in a molded housing made of polyamide 66 which insulates the conductor
and serves as a structural element where clips, bushings, and fastening points are housed. The dielectric
strength (rated voltage at which the insulator breaks down) of polyamide 66 is 24kV. In use, both items are
described as high-voltage assemblies used for the external electrical connection of an electric vehicle’s
battery module, allowing electricity to flow from the battery module to various electrical modules within the
vehicle.
In your request, you suggest that the correct classification for the busbar should be 8536.90.4 000,
Harmonized Tariff Schedule of the United States (HTSUS). We disagree.
The requested heading covers apparatus used to protect, switch, or make connections in electrical circuits. As
evidence, you provide rulings N299890 and N327852, which you state supports your position. However, we
find that the subject items significantly differ from the items in the noted rulings in both form and function.
In our view, the terms of heading 8544, HTSUS, more accurately describe the bars as they are electrically
insulated and appear to be primarily used to facilitate the flow of electricity. As such, heading 8536, HTSUS,
is not applicable.
The applicable subheading for the side mount electrical conductor assemblies will be 8544.60.2000, HTSUS,
which provides for “Insulated (including enameled or anodized) wire, cable (including coaxial cable) and
other insulated electric conductors, whether or not fitted with connectors; optical fiber cables, made up of
individually sheathed fibers, whether or not assembled with electric conductors or fitted with connectors:
Other electric conductors, for a voltage exceeding 1,000 V: Fitted with connectors.” The general rate of duty
will be 3.7 percent ad valorem.
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 Gary Chaffee at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division