CLA-2-90:OT:RR:NC:N1:105
Richard Deutsch
PowerBox-Systems GmbH
Dr.-Friedrich-Drechsler-Str. 35
Donauwoerth 86609
Germany
RE: The tariff classification and country of origin of electronic air-data instruments
Dear Mr. Deutsch:
In your letter dated September 16, 2026, you requested a tariff classification and country of origin
determination ruling.
The first item under consideration is described as the PowerBox CAN-ASA, which is an electronic air-data
instrument designed for aircraft applications, including unmanned aircraft systems (UAS). The device is
equipped with two high-precision digital barometric pressure sensors used to measure static and dynamic
pressure. It electronically processes static pressure to determine the aircraft’s altitude and rate of climb, while
air speed is calculated from the differential between the static and dynamic pressure. The device supports an
airspeed measurement range exceeding 850 km/h and delivers altitude measurements with a relative
resolution of 100 mm. For data transmission and external connectivity, the unit incorporates an integrated
CAN-BUS interface to communicate with flight computers, and it is capable of operating P2-BUS and
EX-BUS telemetry interfaces in parallel. Physical connection to the aircraft’s Pitot-static pressure system is
facilitated via two integrated 3 mm pneumatic connectors. The PowerBox CAN-ASA acts as a processing
instrument that supplies calculated, real-time aircraft air-data information to external flight systems but does
not independently navigate or control the aircraft.
The second item under consideration is described as the Pitot-HASA (Heated Airspeed Altitude), which is an
integrated electronic air-data instrument designed for aircraft applications, including unmanned aircraft
systems. Structurally, the sensor probe incorporates two pressure sensors, a ceramic heating element, an
integrated temperature sensor, a microcontroller, and associated electronic circuitry. Functionally, the
integrated microcontroller processes the raw sensor measurements and outputs comprehensive aircraft
air-data, such as RawAir, True Airspeed (TAS), and Indicated Airspeed (IAS), transmitted through a
DroneCAN interface. To prevent icing and ensure accurate readings, the Pitot head features an actively
regulated heating system capable of maintaining an adjustable operating temperature between approximately
30°C and 50°C. Configuration and firmware updates for the device can be executed via the CAN bus or a
PowerBox Mobile Terminal. The Pitot-HASA functions as a data-gathering instrument that supplies
measured and processed atmospheric flight data to an external flight computer but does not independently
navigate or control the aircraft.
The PowerBox CAN-ASA incorporates a bare printed circuit board (PCB) and housing components of
Chinese origin. Additional electronic and mechanical components are sourced from several countries,
including Germany, Japan, the United Kingdom, and the United States. The Pitot-HASA incorporates a bare
printed circuit board and several mechanical and electromechanical components of Chinese origin.
Additional electronic components are sourced from several countries, including Japan, Taiwan, Germany,
and the United States.
The printed circuit boards used for the PowerBox CAN-ASA and Pitot-HASA are supplied to Germany as
bare, unpopulated and non-functional PCBs. PCB population and electronic assembly are performed in
Germany using surface-mount technology (SMT), through-hole technology (THT), with specialized
electronic manufacturing equipment, and qualified personnel. Following PCB population and inspection, the
completed PCB assemblies remain in Germany for the subsequent product-specific manufacturing
operations. These operations include firmware programming, mechanical and electrical final assembly,
product-specific calibration, functional testing, final quality control and final product approval. All remaining
electronic, mechanical and electromechanical components are combined with the populated PCB assemblies
in Germany to create the finished PowerBox CAN-ASA and Pitot-HASA products.
The applicable subheading for the PowerBox CAN-ASA and the Pitot-HASA will be 9014.20.6000,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Direction finding
compasses; other navigational instruments and appliances; parts and accessories thereof: Instruments and
appliances for aeronautical or space navigation (other than compasses): Other: Other: Electrical.” The general
rate of duty will be free.
When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,
Headquarters Ruling Letter H301619, dated November 6, 2018. The test for determining whether a
substantial transformation will occur is whether an article emerges from a process with a new name,
character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v.
United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See
National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).
Regarding the country of origin of the PowerBox CAN-ASA and the Pitot-HASA, it is our opinion that the
assembly process performed in Germany is considered complex and results in a substantial transformation of
the individual foreign components. Most notably, the creation of the PCBA in Germany using SMT generates
a working PCBA capable of performing measurements. Encapsulating the PCBA with remaining components
only enhances the device. It is our opinion that the manufacturing in Germany creates a new and different
article of commerce with a name, character, and use distinct from the individual components. Accordingly,
the country of origin of the PowerBox CAN-ASA and the Pitot-HASA will be Germany, which is where the
PCBA creation, programming, and final assembly occurs.
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 Jason Christie at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division