10 newer rulings cite the same tariff codes.
Classification can shift over time. Review the more recent rulings below before relying on this one.
The tariff classification of a pump control module from China
Issued April 5, 2018 by U.S. Customs and Border Protection.
Cite this ruling
Copies to clipboardN2 N295361 (April 5, 2018)
Tariff classification
HTS codes: 8537.10.9170
Headings: 8537
Product description
The merchandise under consideration is identified as the Pump Control Module (PCM), part number EM1200, and consists of a circuit board assembly mounted within a molded plastic enclosure. The enclosure is equipped with various plugs, sockets, and terminals which are used to connect the PCM to electronic steering systems in marine vessels/pleasure or commercial boat applications. The PCM is connected to the helm electronic power steering motors, the power steering pumps, the engine electrical network and ignition, and the autopilot if installed. In use, the subject PCM receives wheel movement messages from the helm and electrically controls the hydraulic steering pumps to steer the vessel. In your letter, you indicate that the classification of the EM1200 pump control module should fall under subheading 8413.91.9050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of a hydraulic fluid power pump, would be consistent with the finding in NY Ruling N137235. However, the article at issue differs from the control module in that ruling which is incorporated into a type of pumping machine and is an integral part of the mechanism used to create hydraulic pressure. The EM1200 pump control module is not incorporated into the power steering pumps. It is a separate article that send signals to the pumps. Thus, the EM1200 pump control module is not classifiable as a part of a pump and instead, should be classified in accordance with Note 2a to Section XVI.
CBP rationale
The applicable subheading for the Pump Control Module, part number EM1200 will be 8537.10.9170, HTSUS, which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Other.
Full text
N295361 April 5, 2018 CLA-2-85:OT:RR:NC:N2:220 CATEGORY: Classification TARIFF NO.: 8537.10.9170 Brian Sell Marine Canada Acquisition Inc. dba Seastar Solutions 3831 No. 6 Road Richmond, BC V6V 1P6 Canada RE: The tariff classification of a pump control module from China Dear Mr. Sell: In your letter dated March 20, 2018 you requested a tariff classification ruling. The merchandise under consideration is identified as the Pump Control Module (PCM), part number EM1200, and consists of a circuit board assembly mounted within a molded plastic enclosure. The enclosure is equipped with various plugs, sockets, and terminals which are used to connect the PCM to electronic steering systems in marine vessels/pleasure or commercial boat applications. The PCM is connected to the helm electronic power steering motors, the power steering pumps, the engine electrical network and ignition, and the autopilot if installed. In use, the subject PCM receives wheel movement messages from the helm and electrically controls the hydraulic steering pumps to steer the vessel. In your letter, you indicate that the classification of the EM1200 pump control module should fall under subheading 8413.91.9050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of a hydraulic fluid power pump, would be consistent with the finding in NY Ruling N137235. However, the article at issue differs from the control module in that ruling which is incorporated into a type of pumping machine and is an integral part of the mechanism used to create hydraulic pressure. The EM1200 pump control module is not incorporated into the power steering pumps. It is a separate article that send signals to the pumps. Thus, the EM1200 pump control module is not classifiable as a part of a pump and instead, should be classified in accordance with Note 2a to Section XVI. The applicable subheading for the Pump Control Module, part number EM1200 will be 8537.10.9170, HTSUS, which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Other.” The rate of duty will be 2.7 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 on 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
Ruling history
More rulings on the same tariff codes
The tariff classification of a control panel subassembly from Mexico
The tariff classification, country of origin, and eligibility under the United States-Mexico-Canada Agreement (USMCA) of prefabricated electrical buildings (E-Houses)
The tariff classification of an aluminum electrical cabinet from China
The tariff classification of a printed circuit assembly with a bimetal thermostat from Japan
The tariff classification of a containerized control module from China
The tariff classification of a charging extension cord from Vietnam
The tariff classification of terminal boxes from Korea
The tariff classification of bending rubbers and switch junction ribbons from Hungary
The tariff classification of a volume control PCBA from China
The tariff classification of a rack mounted connector panel from the Netherlands
Follow N295361
Get an email if this ruling is revoked or modified, or a newer ruling supersedes it.
One email per day at most. Confirm your address once, unsubscribe anytime.
Searching CBP rulings the smart way
Rulings are precedent. See which ones apply to your product: TariffLens semantically searches all 200,000+ CBP rulings and builds defensible classifications backed by ruling citations.