RE: The tariff classification of steel assemblies from Sweden

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 N364198 August 31, 2026 CLA-2-73:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7326.90.8688 Amanda Dempsey Dachser Air & Sea Logistics 2000 Arthur Avenue, Unit B Elk Grove Village, IL 60007 RE: The tariff classification of steel assemblies from Sweden Dear Ms. Dempsey: In your letter dated August 11, 2026, you requested a tariff classification ruling on behalf of your client, TectoPower. Informational material was submitted with your request. The products under consideration are steel assemblies used for mounting charging equipment for electric vehicles (EV) and Megawatt Charging Systems (MCS), used for larger vehicles such as buses and semi-trucks. You have described in your request two models: the “Foundation HYC1000 Power Cabinet” and the “Foundation Universal Medium with Alpitronic HYC1000 EV and MCS Mounting Plates.” Both are designed to be installed below ground, are predominately made of steel, and do not contain any electrical components upon importation. The “Foundation HYC1000 Power Cabinet” consists of a rectangular module 800 millimeters (mm) in length, 1500 mm in width, and 844 mm in height. If needed, additional modules can be installed and attached if the mounted equipment requires more surface area. An access hatch is a feature that can be installed if desired using a smaller module with a removable top cover enabling access for maintenance. The “Foundation Universal Medium with Alpitronic HYC1000 EV and MCS Mounting Plates” are designed for two different types of charging equipment: the EV and the MCS. Both items are comprised of two components; a foundation and a mounting plate. The foundation for both items is a rectangular box measuring 650 mm in length, 500 mm in width, and 800 mm in height and is attached to a rectangular plate measuring 940 mm by 790 mm for additional anchorage. The type of plate used to mount the charging equipment depends on which it is intended to support. The EV mounting plate is 680 mm by 530 mm and the MCS mounting plate is 710 mm by 530 mm. In your submission, you suggest the assemblies are correctly classified under heading 8538, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts suitable for use solely or principally
with the apparatus of heading 8535, 8536 or 8537.” Based upon the information provided, in our view, these items are not parts solely or principally provisioned for the mounting of goods of heading 8535, 8536, or 8537 and as such do not meet the terms of the heading. In your submission, you also suggest subheading 8504.90, HTSUS, as an alternative classification. We disagree. Subheading 8504.90, HTSUS, provides for “Electrical transformers, static converters (for example, rectifiers) and inductors; parts thereof: Parts.” The articles do not contain any electrical apparatus, and they do not contribute to the function of converting or altering the input electricity to a converted output. As such, classification under subheading 8504.90, HTSUS, is precluded. With the preclusion of the headings above and absence of electronic components, the merchandise is classifiable under its predominant material, which is steel. Therefore, the assemblies will be classified under Chapter 73, HTSUS, which covers articles made of iron or steel. Heading 7326, HTSUS, is a residual or basket provision which covers a wide range of iron or steel articles that are not more specifically provided for elsewhere in the HTSUS. The Explanatory Notes (ENs) to heading 7326 state that “This heading covers all iron or steel articles obtained by forging or punching, by cutting or stamping or by other processes such as folding, assembling, welding, turning, milling or perforating other than articles included in the preceding headings of this Chapter or covered by Note 1 to Section XV or included in Chapter 82 or 83 or more specifically covered elsewhere in the Nomenclature.” An article of iron or steel can be classified in heading 7326 if it is determined that the item is not more specifically provided for in any other heading of the tariff. These steel assemblies are not specifically covered elsewhere in the tariff. Accordingly, they are classifiable in heading 7326, HTSUS. The applicable subheading for the steel assemblies will be 7326.90.8688, HTSUS, which provides for “Other articles of iron or steel: Other: Other: Other: Other: Other.” The general rate of duty will be 2.9 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 Matthew Gay at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division