CLA-2-87:OT:RR:NC:N2:201
Laura LeTourneau
Rosenbauer Minnesota, LLC
P.O. Box 549 Wyoming, MN 55092
RE: The tariff classification of a self-propelled multi-use robotic chassis from Austria.
Dear Ms. LeTourneau:
In your letter dated June 22, 2023, you requested a tariff classification ruling.
The item under consideration has been identified as the Rosenbauer RTE Robot-800, a self-propelled robotic crawler, which you state is used for multiple purposes including cargo movement, firefighting, and going into locations that would prove hazardous to humans. You state that you are only looking for a classification on the robotic crawler as a standalone at this time, and that any payload module options would be imported as separate items.
You state in your request that:
1) The unit cannot be equipped with a winch or elevating device for self-loading, and that an operator is required when a payload module is exchanged on the crawler itself.
2) The crawler must always be controlled manually and cannot be programmed to carry out a cycle of movements.
3) While the RTE Robot-800 is designed to travel on variable surfaces, which could include warehouses and docks, it is not designed to be used on railways.
4) There are clevises (a U-shaped or forked metal connector within which another part can be fastened by means of a bolt or pin passing through the ends of the connector), for cargo towing located on the front and rear of the RTE Robot-800.
5) The RTE Robot-800 is not designed for use on public roads. The unit is designed to support emergency and firefighting services on paved or unpaved terrain and has stair climbing possibilities.
6) The RTE Robot-800 Robot is a standalone item, designed to accept different payload modules. The payload modules that can be added to the crawler to allow the operator to move goods and equipment or connect to a water source and fight fire with a turret.
The RTE Robot-800 has a maximum speed of 6 kilometers per hour (3.7 mph), a range of 10 kilometers (6.21 miles), and can transverse a slope of >35°, a side slope of >30° and wade up to 20 centimeters (7.87 feet) of water.
You suggest classification in subheading 8479.89, Harmonized Tariff Schedule of the United States (HTSUS). Heading 8479 falls under HTSUS Section XVI which covers “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this Chapter;” However, HTSUS Section XVI Note 1(l) excludes articles of Section XVII, which in turn covers goods of heading 8704. Accordingly, the RTE Robot-800 cannot be classified in subheading 8479.89.
The applicable subheading for the RTE Robot-800 will be 8704.60.0000, HTSUS, which provides for “Motor vehicles for the transport of goods: Other, with only electric motor for propulsion”. The rate of duty will be 25% 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 at https://hts.usitc.gov/current.
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 Matthew Sullivan at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division