The tariff classification of a RoboMIDI and RoboMAX from Italy

N363476
August 4, 2026
CLA-2-84:OT:RR:NC:N1:118
CATEGORY: Classification
TARIFF NO.: 8436.80.0020
Alessandro Cazzin Energreen America Inc. 227 Trade Court Aiken, SC 29805 RE: The tariff classification of a RoboMIDI and RoboMAX from Italy Dear Mr. Cazzin: In your letter dated July 21, 2026, you requested a tariff classification ruling. The merchandise under consideration is identified as the RoboMIDI and RoboMAX, which you describe as two tracked, remote-controlled tool carriers that are designed and marketed primarily for forestry and wild vegetation control. The RoboMIDI and RoboMAX are diesel-powered carriers operated by a multifunction remote with a working range of approximately 492 feet, allowing precise control of movement, steering, and attachment positioning. Both models are offered with multiple track configurations to adapt to varied terrain. The machines are not intended for the transportation of goods or passengers over public roads and are not designed for hauling or pushing. Their functionality is limited to tasks performed via front-mounted work tools. Although each model can accept a range of attachments, their design, construction, and marketing demonstrate a principal purpose in forestry and wild vegetation management. The RoboMIDI commonly carries mulcher and forestry heads, stump grinders, winches, trenchers, and bio-shredders (chippers). The RoboMAX is typically configured with forestry heads (swinging hammers or fixed teeth), a grass/brush head for shrubs, pruner discs, bio-shredders, stump grinders, and stone crushers, with an optional sprayer. You state that U.S. customers overwhelmingly pair these machines with forestry heads, and the machines are imported together with those tools. Without forestry attachments, the machines cannot perform their intended function. While the attachments may be shipped detached for logistics, they are imported together with the machines and are integral to their intended forestry use. The applicable subheading for the RoboMIDI and RoboMAX will be 8436.80.0020, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other agricultural, horticultural, forestry, poultry-keeping or bee-keeping machinery, including germination plant fitted with mechanical or thermal

equipment; poultry incubators and brooders; parts thereof: Other machinery: Forestry machinery. The general rate 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 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 Anthony Grossi at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division