The tariff classification of a vehicle lift, an automated mobile robot, and a pallet buffer from Israel

N362546
July 15, 2026
CLA-2-84:OT:RR:NC:N1:103
CATEGORY: Classification
TARIFF NO.: 8428.90.0390; 8427.10.8050
Gail Cumins Sharretts Paley Carter & Blauvelt PC 75 Broad Street New York, NY 10004 RE: The tariff classification of a vehicle lift, an automated mobile robot, and a pallet buffer from Israel Dear Ms. Cumins: In your letter dated June 24, 2026, you requested a tariff classification ruling on behalf of your client, Five Points Development Group. The merchandise under consideration is referred to as an automated parking system that will include a vehicle lift, two automated mobile robots, a pallet buffer machine, entry room components, chargers, electrical cabinets, and other components. These components will not be confined to a single structural frame, common base, or common housing, but are installed throughout a residential building on different floors and in separate areas. The vehicle lift is designed to lift a pallet (with or without a vehicle) between floors. It is incorporated into a building’s infrastructure and consists of a platform affixed to a vertical frame fitted with rails, a counterweight, a gearmotor, a leveling assembly, sprockets, and lifting chains. The lift is driven by an electric motor, has a 5,100-kilogram load capacity, and moves at 15 meters per minute. The automated mobile robot is designed to transport a pallet (with or without a vehicle) to a dedicated parking spot. It is a self-propelled, battery-powered unit with a rectangular chassis that measures approximately 3,650 millimeters in length, 1,850 millimeters in width, and 340 millimeters in height. Its main components include a screw jack drive unit assembly, an electrical unit, wheel assemblies, and sensors. The robot is fitted with a lifting mechanism, which consists of four screw jacks that are driven by the screw jack drive unit assembly. This mechanism has a 110-millimeter lifting stroke. The pallet buffer is a machine that stacks and stores empty pallets. It consists of two mechanical lifting frame assemblies supported by four adjustable columns. The machine is hydraulically powered and designed to lift up to five pallets. It has a lifting stroke of 700 millimeters and a load capacity of 3,500 kilograms.

In your submission, you suggest that the components, when imported in a single shipment, are classified as a functional unit pursuant to Note 4 to Section XVI under heading 8428 of the Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other lifting, handling, loading or unloading machinery (for example, elevators, escalators, conveyors, teleferics).” We disagree. As noted above, the machines, entry room, and structures are distributed across different floors and throughout the building. The automated mobile robots are free-roaming independent machine robots. The pallet buffer is a stand-alone module that functions independently of the other machines. We do not find that the separate components perform a single, clearly defined function described by heading 8428. Rather, the various machines, components, and systems serve multiple, distinct purposes or fulfill auxiliary functions. Therefore, each component will be separately classified. You cite New York ruling F82199 (February 14, 2000); New York ruling I87239 (October 31, 2002); New York ruling N022821 (February 19, 2008); and New York ruling 805706 (January 31, 1995), in support of classifying the subject system in heading 8428. We find that the machines in the cited rulings are distinguishable from the subject goods. These rulings involved self-contained lifting equipment within a single structure or frame. The applicable subheading for the vehicle lift and pallet buffer will be 8428.90.0390, HTSUS, which provides for “Other lifting, handling, loading or unloading machinery (for example, elevators, escalators, conveyors, teleferics): Other machinery: Other.” The general rate of duty will be free. The applicable subheading for the automated mobile robot will be 8427.10.8050, HTSUS, which provides for “Fork-lift trucks; other works trucks fitted with lifting or handling equipment: Self-propelled trucks powered by an electric motor: Other: Automated guided vehicle (AGV): Other.” The general rate of duty will be free. There is insufficient information to classify the metal pallets, chargers, structural gates, entry room components, electrical cabinet, and other components. As per our meeting on July 1, 2026, these items will need to be addressed separately. 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 P. Forkan Director National Commodity Specialist Division