The tariff classification of a serving robot from South Korea

N335128 September 18, 2023 CLA-2-84:OT:RR:NC:N1:104 CATEGORY: Classification TARIFF NO.: 8479.89.9599 David Cho D & B Customs LLC 3700 Crestwood Pkwy, NW Ste. 815Duluth, GA 30096 RE:  The tariff classification of a serving robot from South Korea Dear Mr. Cho: In your letter dated September 4, 2023, on behalf of your client Hyundai Robotics, you requested a tariff classification ruling. The subject product is the Hyundai S1 Robot, which you describe as an autonomous traveling serving robot.  It is comprised of two sections: a lower driving module and an upper application module.  The driving module includes the controller, motor, battery, and 2D light detection and ranging (LiDAR) sensor.  The upper module has a 3D camera and touch screen display panel.  The upper module also includes three tiered trays whose height and configuration are adjustable.  These trays act as platforms for food, beverages, and dishes that are transported by the robot to and from dining tables in a food service setting. The unit’s trays remain fixed in place while in use.  The robot weighs 60kg and its dimensions are 56 x 56 x 125cm. The robot will be imported with its controller and is preprogrammed with instructions carry out its serving functions. During installation and set-up, the staff manually moves the robot around the establishment where it will be employed to check the locations of the tables and obstacles. The robot’s sensors and ranging system are used to create a “map” which estimates the tables’ position and a travel route is entered through the robot. The staff then interacts with the robot through the user display interface.  Following the horizontal path of the mapped travel route, the robot moves food and beverage items on a tray to a desired table, transports other dining-related items while moving from one table to another, supports staff-initiated tray return by moving to a table for which tray return is needed, and finally supports customer-initiated tray return by moving to a table that requests tray self-return.  The subject robot is not fitted with any handling equipment such as manipulator arms or other types of tooling.  Its function is to provide a surface for manually loaded items and, following user commands, travel to and from and between mapped locations at a restaurant facility.  The robot has a service function but does not lift or handle items. Human actors (wait staff or customers), not the robot itself, move food trays onto and off of both the robot and the dining tables. As imported the robot includes a dedicated charging station with docking port, power cable, and wired charging cable.  It is designed for indoor use only. We note that the subject robot is designed and programmed to function solely in a non-industrial, food service environment. The robot is not reprogrammable for other uses. It has no applications typical of industrial robots, which are intended to replace humans in hostile or dangerous industrial environments, or to perform heavy lifting or repetitive tasks such as boring. The Explanatory Notes to heading 8479 provide examples of typical industrial robot tasks, including welding, handling, loading and unloading, cutting, and assembling articles.    The applicable subheading for the Hyundai S1 Robot will be 8479.89.9599, Harmonized Tariff Schedule of the United States, which provides for “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other: Other: Other”.  The rate of duty will be 2.5 percent 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 at https://hts.usitc.gov/current. 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 arthur.purcell@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division