CLA-2-85:OT:RR:NC:N2:207
Mr. Robert Scott
Curtiss-Wright Controls Integrated Sensing, Inc.
1100 W Grove Pkwy, Ste 102
Tempe, AZ 85283
RE: The tariff classification of parts for motors and sensors from various countries
Dear Mr. Scott:
In your letter dated April 10, 2026, you requested a tariff classification ruling.
There are four items at issue with this request, which are described as components for motors and sensors
incorporated into aircraft: part number 2052-400-001, Rotor Slug; part number 1118-608-005, Primary
Bobbin; part number 1004-111-049, Stator Winding Assembly; and part number 513-7051-00, Sleeve.
Part number 2052-400-001, Rotor Slug, is a subcomponent of a DC stepper motor which is mounted onto a
gear motor shaft to become a rotor assembly. The rotor assembly is a component in a stepper motor. The
Rotor Slug transfers magnetic flux through the rotor and the stepper motor is used to control a valve which
controls the fuel flow to an aircraft engine. This subcomponent is made of steel alloy and the country of
origin is Canada.
Part number 1118-608-005, Primary Bobbin, is a part of a rotary position sensor which is referred to as a
resolver or an inductive sensor. It features a round bobbin tube with two flanges where the primary coil can
be wound in a precise manner and contained within the two flanges. This component is made from Ultem®
2300 polymeric plastic and the country of origin is Canada.
Part number 1004-111-049, Stator Winding Assembly, is a component of a Rotary Variable Differential
Transformer (RVDT) which is a rotary position sensor. The stator winding assembly is comprised of a stator
lamination stack, copper windings, lead wires, and insulator material. It creates magnetic flux through the
excitation windings and conveys that flux through the rotor assembly back to the output differential windings
which enable conversion to a mechanical output position. You state that the country of origin for this
assembly is Costa Rica.
Part number 513-7051-00, Sleeve, is a round tube with a reduced end made of Inconel® X-750, a nickel
chromium alloy. This cut-to-size tube has a ½ inch diameter and is a part of a RVDT (Rotary Variable
Differential Transformer) rotary position sensor, part number 25534. You state that the component is made
in Mexico.
In your request, you suggest that part number 2052-400-001, Rotor Slug, is correctly classified under
subheading 8503.00.9520, Harmonized Tariff Schedule of the United States (HTSUS). You also suggest that
part numbers 1118-608-005, Primary Bobbin, and part number 1004-111-049, Stator Winding Assembly, are
correctly classified under subheading 8543.90.8885, HTSUS. Lastly, you propose part number 513-7051-00,
Sleeve, is correctly classified under subheading 7507.12.0000, HTSUS. We agree.
The applicable subheading for part number 2052-400-001, Rotor Slug, will be 8503.00.9520, HTSUS, which
provides for “Parts suitable for use solely or principally with the machines of heading 8501 or 8502: Other:
Other: Parts of motors.” The general rate of duty will be 3 percent ad valorem.
The applicable subheading for part numbers 1118-608-005, Primary Bobbin, and 1004-111-049, Stator
Winding Assembly, 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 applicable subheading for part number 513-7051-00, Sleeve, will be 7507.12.0000, HTSUS, which
provides for “Nickel tubes, pipes and tube or pipe fittings (for example, couplings, elbows, sleeves): Tubes
and pipes: Of nickel alloys.” The general rate of duty will be 2 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 Howard Suh at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division