The tariff classification of blender base assembly imported with or without the blade assembly and jar from China

N343115 November 5, 2024 CLA-2-85:OT:RR:NC:N4:410 CATEGORY: Classification TARIFF NO.: 8509.40.0015 Paul Nielson Merit Trade Consulting Service 40864 N Tumbleweed TrailSan Tan Valley, AZ 85140 RE:  The tariff classification of blender base assembly imported with or without the blade assembly and jar from China Dear Mr. Nielson: In your letter dated October 7, 2024, on behalf of Electro Motor, Inc. & OptiMotor LLC, you requested a tariff classification ruling. The merchandise is identified as the blender base assembly imported with or without the blade assembly and the jar. The blender base assembly is for the desktop blender that consists of a plastic housing containing an electric motor, Printed Circuit Board (PCB) and other electric components. It is equipped with a switch and power cord. The blender base assembly will be imported in the following three scenarios: The import of just the complete base assembly, without the blade assembly or the jar. The import of the complete base assembly and the jar, without the blade assembly. The import of the complete base assembly and the blade assembly, without the jar. It is stated in your submission that the complete blender will be comprised of the blade assembly and the jar for use in the household to make smoothie drinks. We are of the view that the blender base assembly, imported in all of the above three scenarios, is considered an incomplete blender with the base assembly having the essential character of the complete blender, General Rules of Interpretation (GRI) 2 (a) noted. Accordingly, the applicable subheading for subject products will be 8509.40.0015, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electromechanical domestic appliances, with self-contained electric motor, other than vacuum cleaners of heading 8508; parts thereof: Food grinders, processors and mixers; fruit or vegetable juice extractors: Blenders”. The general rate of duty will be 4.2 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/. 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 Michael Chen at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division