CLA-2-84:OT:RR:N1 104

Jennifer Diaz
Diaz Trade Law, P.A.
12700 Biscayne Blvd., Suite 401
North Miami, FL 33181

RE: The tariff classification of electric vessel fin stabilizer systems and a vessel steering system from Italy

Dear Ms. Diaz:

In your letter dated April 30, 2026, you requested a tariff classification ruling on behalf of your client, CMC Marine Corp.

The products in question are described as electric vessel fin stabilizer systems, models HS60, LR250, STAB 25, and STAB 40, and an electric vessel steering system, model DIRECTA 120. These complete, electro-mechanical automatic systems employ motors, electronics, and other apparatus to stabilize or steer water yachts.

The HS and LR fin stabilizer systems consist of (1) hydrodynamic fins to stabilize a vessel; (2) an actuator that rotates the fins; (3) an inertial platform to feed a yacht’s movement data into an Electronic Control Unit panel; (4) Electronic Power Unit panels which contain servos to feed the electric motors; (5) Electronic Control Unit panel containing the CPU which reads all data and commands the actuators’ movement; and (6) a touchscreen control monitor. The actuator assembly consists of a brushless electric motor, gearbox, main flange, motor encoder, fin encoder, lubrication port, and a tapered shaft. Unlike the HS and LR systems, the STAB stabilizer systems are shaftless. They consist of (1) high hydrodynamic efficiency active fins; (2) actuators (with electrical motors and gearbox) for fin rotation; Electronic Power Unit panels; (3) an Electronic Control Unit panel; (4) inertial platform; and (5) a touchscreen control monitor. The HS, LR, and STAB stabilizer systems control the roll, pitch, and yaw of a vessel through rotational movements.

The DIRECTA steering system consists of (1) two electric linear actuators, with each consisting of a recirculating ball screw actuator drive by a main motor, with most models being equipped with a backup gear motor; (2) two electric motors; (3) control switchboard; (4) junction box; (5) Wheelhouse Control Station providing user interface to control the system by touchscreen, an encoder connected to the rudder wheel, and an interface to the autopilot system; (6) Flybridge Control Station with a rudder wheel, touchscreen, and an encoder connected to the rudder wheel; and (7) Wing Control Station which includes a touchscreen with buttons, rudder angle indicators, monitoring an alarm pages. The DIRECTA steering system controls the direction of a vessel.

In your submission, you suggest that the subject articles are correctly classified under heading 8501, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric motors and generators (excluding generating sets):”. We disagree. The vessel stabilizer and steering systems do use electric motors for the rotary motion required to turn the fins or rudders, but they also include other components or equipment outside of heading 8501 to form a complete system. Consequently, the subject articles are precluded from classification within heading 8501.

The applicable subheading for both the electric vessel fin stabilizer systems, models HS60, LR250, STAB 25, and STAB 40, and the electric vessel steering system, model DIRECTA 120, each imported together as a complete system with the above-referenced components, will be 8479.89.9599, HTSUS, which provides for “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other: Other: Other.” The general rate of duty will be 2.5 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 Arthur Purcell at [email protected].
Sincerely,

(for)
James P. Forkan
Director
National Commodity Specialist Division