CLA-2-85:OT:RR:NC:N2:220
Mr. Dustin Thigpen
Andrew/Amphenol
2601 Telecom Parkway
Richardson, TX 75082
RE: The tariff classification of an aluminum electrical cabinet from China
Dear Mr. Thigpen:
In your letter dated April 3, 2026, you requested a tariff classification ruling.
The merchandise under consideration is an aluminum electrical cabinet identified by part number 860667068
and is described as an aluminum cabinet designed to house and protect electrical components that are added
after importation such as power distribution equipment, fiber optic equipment, and other electrical
equipment. We note that in its imported condition the cabinet contains a number of electrical components
including an uninsulated bus bar, a terminal block, and copper grounding cables.
In your request, you suggest that the correct classification for the aluminum cabinet should be 8538.10.0000,
Harmonized Tariff Schedule of the United States (HTSUS). We disagree. Subheading 8538.10 provides for
cabinets or other bases, not equipped with their apparatus. The subject cabinets are imported with an
uninsulated bus bar and a terminal block, both of which are classified in heading 8536 and therefore does not
meet the terms of subheading 8538.10 “not equipped with their apparatus.”
The applicable subheading for the aluminum electrical cabinet will be 8537.10.9170, HTSUS, which
provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus
of 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V:
Other: Other: Other.” The general rate of duty will be 2.7 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