CLA-2-85:OT:RR:NC:N2:220
Ismar Ibrahimpasic
Prismatik Dentalcraft, Inc.
4141 MacArthur Blvd
Newport Beach, CA 92660
RE: The tariff classification of the F2 Electrical Enclosure Assembly from China
Dear Mr. Ibrahimpasic:
In your letter dated May 22, 2026, you requested a tariff classification ruling.
The merchandise under consideration in this request is the F2 Electrical Enclosure Assembly, which is
described as a base structure of sheet metal construction designed to be the mounting surfaces for electrical
components including the main control board (a printed circuit board assembly (PCBA) populated with
numerous electrical components), a programmable logic controller, an etherCAT coupler module, a serial
communications module, a 16-channel digital input module, a 16-channel digital output module, a 1-channel
servomotor drive module, two 1-channel stepper motor drive modules, a cooling fan, and several electrical
cables. In use, the subassembly functions as the “brain” of the Fastmill.io dental milling machine where it
provides electrical power and control to other components of the dental milling machine. One of the main
components of the F2 Electrical Enclosure Assembly is a programmable logic controller, which is
programmed with proprietary software that the end user accesses through a custom user interface program via
an accompanying computer. The end user is guided by a series of on-screen prompts generated by this
software in order to use the dental milling machine.
You suggest classification of the F2 Electrical Enclosure Assembly, which is a subassembly of the Fastmill.io
dental milling machine, in subheading 9018.49.8080, Harmonized Tariff Schedule of the United States
(HTSUS), which provides for “Instruments and appliances used in medical, surgical, dental or veterinary
sciences, including scintigraphic apparatus, other electro-medical apparatus and sight-testing instruments;
parts and accessories thereof: Other: Other: Other.” Although the F2 Electrical Enclosure Assembly may be
intended for use with the Fastmill.io dental milling machine of heading 9018, Note 2(a) to Chapter 90 states
that parts and accessories which are goods included in any of the headings of chapter 84, 85, or 91 are in all
cases to be classified in their respective headings. Therefore, if the F2 Electrical Enclosure Assembly is
classifiable under Chapter 84, 85 or 91, then it would be excluded from classification in subheading
9018.49.8080, in accordance with Note 2(a) to Chapter 90.
The applicable subheading for the F2 Electrical Enclosure Assembly will be 8537.10.9160, HTSUS, which
provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus
of heading 8535 or 8536, for electric control or the distribution of electricity, including those incorporating
instruments or apparatus of chapter 90, and numerical control apparatus, other than switching apparatus of
heading 8517: For a voltage not exceeding 1,000 V: Other: Other: Programmable Controllers.” 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