The tariff classification of photovoltaic (PV) generators from France

N332218 April 19, 2023 CLA-2-85:OT:RR:NC:N2:220 CATEGORY: Classification TARIFF NO.: 8501.72.1000 Jennifer Guay Metro Customs Brokers 1 Lincoln Blvd Rouses Point, NY  12979                                                                                 RE:      The tariff classification of photovoltaic (PV) generators from France   Dear Ms. Guay: In your letter dated April 12, 2023, you requested a tariff classification ruling on behalf of your client, Sunforce Products Inc. The first item under consideration is identified as the 175W 12-Volt Crystalline Solar Panel (PV generator), Model Number 38175, which is described as an aluminum framed crystalline solar generator having a glass surface, a back sheet, a junction box, and output cables.  You state that the crystalline cells are manufactured in France, and that this model of PV generator is sold as a 12 V battery charger and can be used in RVs, homes, and boats, as well as a back-up and remote power source.  Based on the information provided, the PV generator connects directly to the electrical load, such as an RV’s inverter to supply generated electricity.  You state the maximum power output of this PV generator is 175 W. The second item under consideration is identified as the 175W 12-Volt Crystalline Solar Panel, Model Number 38181, which is the same as the previous PV generator, and is also described as an aluminum framed crystalline solar generator having surface glass, a back sheet, a junction box, and output cables.  You state that the crystalline cells are manufactured in France, and that this model of PV generator is sold as a 12 V battery charger and can be used in RVs, homes, and boats, as well as a back-up and remote power source.  Based on the information provided, the PV generator connects directly to the electrical load, such as an RV’s inverter to supply generated electricity.  You state the maximum power output of this PV generator is 175 W. The applicable subheading for the 175 W 12-Volt Crystalline Solar Panel, Model Number 38175, and the 175W 12-Volt Crystalline Solar Panel, Model Number 38181, will be 8501.72.1000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric motors and generators (excluding generating sets): Photovoltaic DC generators: Of an output exceeding 50 W: Of an output not exceeding 750 W”.  The general rate of duty will be 2.5 per cent ad valorem. 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 Karl Moosbrugger at karl.moosbrugger@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division