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