CLA-2-85:OT:RR:NC:N4:410
Ms. Michelle Campbell
Catalyst Customs Brokers, Inc.
2252 Landmeier Road, Suite B
Elk Grove Village, IL 60007
RE: The tariff classification of a robotic vacuum cleaner from China
Dear Ms. Campbell:
In your letter dated June 3, 2022, you requested a tariff classification ruling on behalf of Ecovacs Robotics Co., Ltd. Pictures and product specifications were submitted with your request.
The product is identified as the YEEDI Model DVX46, K850+ (the “K850+”). Based on the information and pictures that you have provided, the K850+ is in a round shape measuring approximately 508mm in diameter and 474mm in height. This model is rated 40W with the dust bin capacity of 300 ml and designed for domestic use only. It is stated that the K850+ suctions up the debris with the side brush, the main brush rotates to sweep the dust to the suction port from both sides, and then the washable mopping pads “mop” the floor to complete the process of floor cleaning. The suction is effected by means of a turbine fixed directly onto the shaft of the motor turning at high velocity. The dust and other materials are collected in an internal or external dust bag/receptacle, whereas the air suctioned in and filtered is also used to cool the motor. After the floor cleaning task is completed, the robot will return to the Self-Cleaning Station through the corresponding interface to make a self-cleaning procedure. The Self-Cleaning Station is designed to collect dust, clean mopping pads, dry mopping pads, and refill the water tank as well as charge the robot.
The applicable subheading for the K850+ will be 8508.11.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Vacuum cleaners, parts thereof: With a self-contained electric motor: Of a power not exceeding 1,500 W and having a dust bag or other receptacle capacity not exceeding 20 l”. The rate of duty will be Free.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8508.11.0000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8508.11.0000, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading.
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 Michael Chen at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division