The tariff classification of an enclosure weldment from China

N359756
March 27, 2026
CLA-2-85:OT:RR:NC:N1:103
CATEGORY: Classification
TARIFF NO.: 8507.90.8000
Paul Biegen Our Next Energy, Inc. 45145 West 12 Mile Road Novi, MI 48377 RE: The tariff classification of an enclosure weldment from China Dear Mr. Biegen: In your letter dated March 16, 2026, you requested a tariff classification ruling. The merchandise under consideration is referred to as a bent enclosure weldment, part number 100074388, which serves as a structural enclosure for an electric battery pack. The weldment is made from steel sheet metal and is open on three sides (front, rear, and top). It is designed for a specialized 72 VDC auxiliary battery pack used in DC energy storage applications for rail systems. Typical applications include engine start support and powering hotel loads (e.g., non-propulsion electrical loads such as lighting, HVAC, etc.) on locomotives. In the United States, lithium iron phosphate battery cells and a battery management system are mounted in the enclosure, which is then sealed by a rear plate, a lid, and a front plate assembly. The applicable subheading for the bent enclosure weldment, part number 100074388, will be 8507.90.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric storage batteries, including separators therefor, whether or not rectangular (including square); parts thereof: Parts: Other.” The general rate of duty will be 3.4 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the

classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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 Paul Huang at [email protected].
Sincerely,
(for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division