The tariff classification of vacuum trucks from the Netherlands

N310558 March 20, 2020 CLA-2-87:OT:RR:NC:N1:101 CATEGORY: Classification TARIFF NO.: 8705.90.0000 Remco Ter Heedt Koks United States Corporation 402 HWY 146 South La Porte, Texas 77571 RE: The tariff classification of vacuum trucks from the Netherlands Dear Mr. Ter Heedt: In your letter dated March 10, 2020, you requested a tariff classification ruling. The item under consideration is identified as an industrial vacuum truck. The Gross Vehicle Weight (G.V.W.) of the vacuum truck is approximately 42,000 pounds. The industrial vacuum truck is designed to collect and remove/transport fluids, powders, sludge slurry, and other waste. These trucks are specifically designed for suctioning and transporting wet or dry hazardous and non-hazardous materials. A vacuum pump is utilized along with other vacuum apparatus to clean/remove debris and other waste from the jobsite. Their design consists of vacuum tanks mounted onto a chassis. You state that the truck chassis is US manufactured, with a vacuum installation as a superstructure. The vacuum superstructure is built and assembled at your factory in the Netherlands. You suggested classification in subheading 8705.90.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Special purpose motor vehicles, other than those principally designed for the transport of persons or goods (for example, wreckers, mobile cranes, fire fighting vehicles, concrete mixers, road sweepers, spraying vehicles, mobile workshops, mobile radiological units): Other.” This office concurs. HQ Ruling H235508 dated August 27, 2014, references a similar issue. The applicable classification subheading for the industrial vacuum truck will be 8705.90.000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Special purpose motor vehicles, other than those principally designed for the transport of persons or goods … : Other.” The rate of duty will be Free. 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 on the World Wide Web at https://hts.usitc.gov/current. This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Matthew Sullivan at matthew.sullivan@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division