The tariff classification of an energy storage cabinet kit from Thailand

N363422
July 31, 2026
CLA-2-44:OT:RR:NC:N5:463
CATEGORY: Classification
TARIFF NO.: 7309.00.0090
Ms. Yolanda Zhang Minth Group Pan American Automotive Parts Trading LLC 602 Brents Road Lewisburg, TN 37091 RE: The tariff classification of an energy storage cabinet kit from Thailand Dear Ms. Zhang: In your letter, dated July 18, 2026, you requested a binding tariff classification ruling on an energy storage cabinet. Product information and photos were submitted for our review. The product under consideration is an energy storage cabinet. You describe the cabinet as being imported in unassembled form, but complete, and then assembled in the United States. You describe the cabinet as "Complete Knocked Down” and designed for use in a “Battery Energy Storage System”. The cabinet measures 6058mm by 2438mm by 2896mm, or 42,722 liters in volume. It is constructed of steel. The steel cabinet does not contain any electrical or mechanical components at time of importation. The cabinet is designed to hold batteries and electrical equipment to function as a power source. The unassembled cabinet includes wall modules, a floor module, a roof module, and battery racks. You state that the energy storage cabinet structure divides the interior into dedicated compartments for battery modules, electrical equipment, control systems, and thermal management equipment. In your submission, you suggest that the subject energy storage cabinet is classifiable under subheading 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.” We disagree. In HQ ruling H356254, dated April 14, 2026, Customs reviewed a container similar in construction and function to the subject cabinet. Both cabinets are used to house batteries and electrical equipment, serving as protective enclosures for environmental protection. They are not integral components of a battery cell, battery module, or battery unit, and do not contribute to the storing or supplying of electrical energy. Therefore, classifying the subject cabinet in heading 8507 is not appropriate. Classification of merchandise under the HTSUS is in accordance with the General Rules of Interpretation (GRIs). GRI 2(a) states:

Any reference in a heading to an article shall be taken to include a reference to that article incomplete or unfinished, provided that, as entered, the incomplete or unfinished article has the essential character of the complete or finished article. It shall also include a reference to that article complete or finished (or falling to be classified as complete or finished by virtue of this rule), entered unassembled or disassembled. The energy storage cabinet kit is the complete cabinet, but unassembled. In accordance with GRI 2(a), the unassembled storage cabinet will be classified in the same manner as a fully assembled storage cabinet. The cabinet is a container of steel. The applicable subheading for the energy storage cabinet will be 7309.00.0090, HTSUS, which provides for Reservoirs, tanks, vats and similar containers for any material (other than compressed or liquefied gas), of iron or steel, of a capacity exceeding 300 liters, whether or not lined or heat insulated, but not fitted with mechanical or thermal equipment: Other. The general rate of duty will be free. 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 Claudia Lin at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division