RE: The tariff classification of electric actuator assembly from Mexico

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 N364070 August 24, 2026 CLA-2-85:OT:RR:NC:N2 207 CATEGORY: Classification TARIFF NO.: 8501.31.4000 Martha Carrillo Cabrera Infac Automotive Mexico SA DE CV Antiguo Camino A Hermanas, No. Ext. 300, Estancias de San Juan Bautista, C.P. 25733, Monclova, Coahuila, Mexico RE: The tariff classification of electric actuator assembly from Mexico Dear Ms. Carrillo Cabrera: In your letter dated August 5, 2026, you requested a tariff classification ruling. The merchandise under consideration is described as Caliper-Integrated Electronic Parking Actuator Assembly, part number 51784330, which is an electro-mechanical actuator designed exclusively for use in an automotive Electronic Parking Brake (EPB) system. The assembly is comprised of a 12V brushed DC motor with maximum power output of 200W, multi-stage planetary reduction gears, a lead screw, seals, and electrical terminals housed in a plastic enclosure. The actuator assembly is intended to be mated to a compatible brake caliper assembly to generate linear force that actuates the brake piston to apply or release the brake. We note that the brake calipers and brake pistons are not imported with the actuator assembly. You suggest the tariff classification for the EPB Actuator Assembly under the subheading 8708.30.5090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Brakes and servo-brakes; parts thereof: For other vehicles: Other.” We disagree. The imported article is a complete electro-mechanical actuator incorporating a permanently integrated brushed DC electric motor, reduction gear assembly, lead screw mechanism, and associated electrical components. Although the actuator is designed solely for installation in an automotive electronic parking brake system, Section XVII, Note 2(f), HTSUS, excludes from classification in Chapter 87 “electrical machinery or equipment (Chapter 85).” Consequently, the presence of a dedicated automotive application does not overcome the legal exclusion contained in Note 2(f). Accordingly, the article is precluded from classification as a part of a motor vehicle of heading 8708.
The applicable subheading for the Caliper-Integrated Electronic Parking Actuator Assembly, part number 51784330, will be 8501.31.4000, HTSUS, which provides for “Electric motors and generators (excluding generating sets): Other DC motors; DC generators, other than photovoltaic generators: Of an output not exceeding 750 W: Motors: Exceeding 74.6 W but not exceeding 735 W.” The general rate of duty will be 4 percent ad valorem. 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 Howard Suh at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division