CLA-2-85:OT:RR:NC:N2:220
Filipp Zaborenko
Schaeffler Group USA Inc.
308 Springhill Farm Road
Fort Mill, SC 29715
RE: The tariff classification of electric motors from Germany
Dear Mr. Zaborenko:
In your letter dated October 31, 2022, you requested a tariff classification ruling.
The first item under consideration is identified as the Beam E-Axle Electric Drive Motor Assembly (Beam Motor), which consists of a 375 kW electric motor, a gearbox, and an inverter. You describe the gearbox and the inverter as being physically incorporated into the motor assembly, where the gearbox converts the rotational force of the motor into applied propulsion for the vehicle. However, the inverter performs multiple functions, such as converting vehicle DC current into AC current for motor operation, electrical control of the motor, communication with vehicle electrical systems, and converting the AC current produced from the axle into DC current to charge the vehicle batteries.
The second item under consideration is identified as the X83F E-Axle Electric Drive Motor Assembly (X83F Motor), which consists of a 200 kW electric motor, a gearbox, and an inverter. Like the Beam Motor, you describe the gearbox and the inverter as being physically incorporated into the motor assembly and both perform the same function(s) as described above. We would note that both the Beam Motor and the X83F Motor utilize DC and AC current to function, but it is the converted AC current that is applied to the motor’s stator which produces the rotational torque for each of the subject motors.
As described, the electric motors consist of multiple apparatus and/or machines that contribute to the overall operation/function of the electric motor. Each of the additional machines described are incorporated into/onto the E-Axle motors, such as the gearbox and inverter. However, it is our view that the additional apparatus, which are combined with an electric motor, serve to facilitate and support the motor’s function and operation.
In your letter, you supply ruling letters HQ 086832 and NY N322256 and suggest the Beam Motor is classifiable under subheading 8501.53.8060 and the X83F Motor is classifiable under subheading 8501.53.8040, Harmonized Tariff Schedule of the United States (HTSUS). We agree.
The applicable subheading for the Beam E-Axle Electric Drive Motor Assembly will be 8501.53.8060, HTSUS, which provides for “Electric motors…: Other AC motors, multi-phase: Of an output exceeding 75kW: Other: Other.” The general rate of duty will be 2.8%.
The applicable subheading for the X83F E-Axle Electric Drive Motor Assembly will be 8501.53.8040, HTSUS, which provides for “Electric motors…: Other AC motors, multi-phase: Of an output exceeding 75kW: Other: Not exceeding 373 kW.” The general rate of duty will be 2.8%.
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