CLA-2-84:OT:RR:NC:N1:104
David Cho
D & B Customs LLC
3700 Crestwood Pkwy NW
Ste. 815 Duluth, GA 30096
RE: The tariff classification of mobile robot from South Korea
Dear Mr. Cho:
In your letter dated September 4, 2023, on behalf of your client Hyundai Robotics, you requested a tariff classification ruling.
The subject product is the Hyundai B1 Robot, which you describe as a self-navigating autonomous mobile robot designed for dynamically moving material in challenging environments. As imported it is comprised of a flat-surfaced main body driving module which includes the controller, motor, battery, 2D light detection, a 3D camera, and a ranging (LiDAR) sensor. The robot weighs 38kg and its dimensions are 520 x 550 x 327mm. Its maximum payload is 50kg. It is designed for indoor use only.
The robot will be imported with its controller and open-source software but is not preprogrammed. Designed for developers, integrators, and end-users, the system can be programmed by the user to carry out various customized applications and payloads. While the robot is designed primarily for moving material, you provide several examples of other uses including manufacturing, warehousing, clean technology, and laboratories. As imported the B1 robot is not fitted with any handling equipment such as manipulator arms or other types of tooling but is capable of working with such items.
As imported the robot includes a dedicated charging station with docking port, power cable, and wired charging cable.
The applicable subheading for the Hyundai B1 Robot will be 8479.50.0000, Harmonized Tariff Schedule of the United States, which provides for “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Industrial robots, not elsewhere specified or included”. The rate of duty will be 2.5 percent 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.
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 Arthur Purcell at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division