The tariff classification of a solar-powered trailer from China

N361432June 3, 2026CLA-2-85:OT:RR:NC:N2 207
CATEGORY: Classification
TARIFF NO.: 8541.43.0010
Mikel HongGrandchb Inc.602 South Wilton Place, Unit 105Los Angeles, CA 90005RE: The tariff classification of a solar-powered trailer from ChinaDear Mr. Hong:In your letter dated
May 11, 2026
, you requested a tariff classification ruling on behalf of your client, EPOSecurity Solutions.The merchandise under consideration is described as a solar-powered trailer, Model Number LMT-6.7M,which is a wheeled trailer fitted with solar panels. The mobile trailer is comprised of two wheels on a singleaxle featuring a wedge-shaped steel enclosure with a sloped upper deck that integrates two solar panels. Thetrailer also includes a tow hitch, and stabilizing support legs. You state that the trailer is not self-propelledand designed to be transported by towing. The incorporated solar panels will have split-type junction boxesand two cables affixed with MC4 connectors. However, they do not include any inverters, batteries, chargingcontrollers, or similar power management devices. Additionally, the steel enclosure is a bare metal cabinetwithout any internal components, electrical systems, or pre-installed wiring. After importation into the UnitedStates, the trailer will be equipped with additional components such as cameras, recording and networkingdevices, an inverter, and a controller to build a complete mobile security trailer.The applicable subheading for the solar-powered trailer, Model Number LMT-6.7M, will be ,8541.43.0010Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Semiconductor devices (forexample, diodes, transistors, semiconductor-based transducers); photosensitive semiconductor devices,including photovoltaic cells whether or not assembled in modules or made up into panels;…Photosensitivesemiconductor devices, including photovoltaic cells whether or not assembled in modules or made up intopanels; light-emitting diodes (LED): Photovoltaic cells assembled in modules or made up into panels:Crystalline silicon photovoltaic cells of a kind described in statistical note 12 to this chapter.” The generalrate of duty will be Free.
The duties cited above are current as of this ruling’s issuance. 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 providedat https://hts.usitc.gov/.Please note that this product may be subject to antidumping duties or countervailing duties (AD/CVD). Whenthere is a question as to whether merchandise is subject to an antidumping or countervailing duty order orconsidered to be defined by the scope of an order, such a determination is governed by the U.S. Departmentof Commerce’s International Trade Administration (“Commerce”). Commerce issues scope rulings todetermine whether merchandise which is in commercial production is covered by the scope of anantidumping or countervailing duty order. Commerce’s scope rulings are separate and distinct from decisionsissued by CBP regarding tariff classification and country of origin for purposes such as duty assessment andmarking.To seek a scope ruling, please visit the website of Commerce’s International Trade Administration. A guideto seeking a scope ruling can be found at . A list of current AD/CVDhttps://access.trade.gov/help/Scope_Ruling_Guidance_(4.1.2022).pdfinvestigations at the United States International Trade Commission can be viewed on its website at . Additionally, messages sent by Commerce to CBP regarding AD/CVD cash depositshttp://www.usitc.govand liquidation can be searched using ACE or CBP’s search tool at .https://trade.cbp.dhs.gov/ace/adcvd/adcvd-public/#This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties 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 eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems 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.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to theclassification stated above, the merchandise covered by this ruling may also need to be reported with eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems 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 asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Howard Suh at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division