CLA-2-85:OT:RR:NC:N2:220
Dan Ford
Mitsubishi Electric Automotive America, Inc.
4773 Bethany Road
Mason, OH 45040
RE: The tariff classification of electric drive motors from Japan
Dear Mr. Ford:
In your letter dated September 14, 2021, you requested a tariff classification ruling.
The merchandise under consideration is identified as the Power Steering Motor Control Units (MCU), which are described as permanent magnet, three-phase, synchronous, AC motors, each having an integrated controller, position sensor, and a power inverter. You state that the five motors are all similar in construction and function, having a maximum rated output of either 475 Watts or 477 Watts and are intended for use in steering systems of consumer and commercial vehicles.
In your letter, you state that the MCUs receive 12VDC electricity directly from the vehicle and the internal inverter converts the DC electricity to usable AC for the motor’s operation. We would note that the classification of electric motors is dependent upon many factors, such as the type of electricity applied to the motor and/or the maximum power output, as measured in Watts, for example. With the instant motors, you state that the direct current applied to the motor must be converted to AC for the motors to function. In our view, the type of electricity that is applied to a motor’s stator determines what type of motor it is for classification purposes. As such, we are of the opinion that the MCUs under consideration here are AC motors because that is the type of electricity that produces the rotation.
In your request, you suggest the MCUs are properly classified under subheading 8501.51, Harmonized Tariff Schedule of the United States, (HTSUS). We agree.
The applicable subheading for the subject MCUs will be 8501.51.4040, HTSUS, which provides for “Electric motors and generators (excluding generating sets): Other AC motors, multi-phase: Of an output not exceeding 750 W: Exceeding 74.6 W but not exceeding 735W: Other”. The general rate of duty will be 2.5% ad valorem.
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 on the World Wide Web at https://hts.usitc.gov/current.
This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Karl Moosbrugger at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division