RE: The tariff classification of steel weldment components of a robotic manufacturing cell from Thailand

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N363902 August 18, 2026 CLA-2-84:OT:RR:NC:N1:104 CATEGORY: Classification TARIFF NO.: 8479.90.9591 Kristi Stahli Machina Labs, Inc. 20559 Prairie St. Chatsworth, CA 91311 RE: The tariff classification of steel weldment components of a robotic manufacturing cell from Thailand Dear Ms. Stahli: In your letter dated July 31, 2026, you requested a tariff classification ruling. The items in question are five (5) steel frame weldments engineered specifically for Machine Lab’s RoboCraftsman Cell containerized robotic industrial forming system. The RoboCraftsman Cell employs two programmed, synchronized industrial robotic arms (manipulators) to shape sheet metal incrementally without using hard dies or molds, a process referred to as roboforming. The RoboCraftsman Cell’s robotic arms are also programmed to cut and drill material by changing the manipulator’s end-of-arm tooling. The Cell also laser scans the material for measurements, adjustments, and quality control. Neither the robotic manipulators nor any other components of the RoboCraftman Cell will be imported with the five subject weldments. The first item, #4-01710, is the Weldment Base Frame R1. This component serves as the structural platform for the RobotCraftsman Cell. The industrial robot mounts to a carriage plate that interfaces with a gear rack installed on the rail structural weldment that is then installed to the side frame weldment. This assembly is bolted to both the based frame weldment and the floor. The second item, #4-01885, is the Weldment Base Frame R2. This component is similar the #4-01710 Weldment Base Frame R1. The third item, #4-01643, is the Weldment Forming Frame. This fixture component serves as the material supporting structure for the RoboCraftsman Cell. The fixture is mounted to the base frames and supports the sheet metal to be processed by the industrial robots. The four item, #4-01949, is the Weldment Rail Structure, High Capacity. This component serves as the structural platform for the RoboCraftsman Cell. The industrial robot mounts to a carriage plate that interfaces with a gear rack installed on this structure.
The fifth item, #4-02051, is the Weldment Side Frame. This component serves as the structural platform for the RoboCraftsman Cell. The industrial robot mounts to a carriage plate that interfaces with a gear rack installed on the structural rail weldment that is then installed to this side frame weldment. In your submission, you state that all five weldments are specifically designed to enable robotic, dual-sided incremental forming, scanning, and cutting of sheet metal parts. The weldments include features such as reinforcement gussets, passthroughs for electronics, and precision alignment features for maintaining robot accuracy during operation. These features enable a platform for robotic forming, scanning, cutting, drilling, and potentially other manufacturing operations not currently developed. The applicable subheading for the structural machined frame weldments will be 8479.90.9591, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter, parts thereof: Parts: Other: Other: Other. 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 Arthur Purcell at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division