The tariff classification of four electric trailer dollies from Canada

N360723 April 24, 2026 CLA-2-87:OT:RR:NC:N2:201 CATEGORY: Classification TARIFF NO.: 8701.10.0100; 8701.91.5000 Mr. Mike Ferris Strader Ferris International 808 Commerce Park Drive Ogdensburg, NY 13669-2208 RE: The tariff classification of four electric trailer dollies from Canada Dear Mr. Ferris: In your letter dated April 14, 2026, you requested a tariff classification ruling, on behalf of your client, Parkit360 Inc., located in Carleton Place, Canada. The items under consideration have been identified as four (4) models of electric powered trailer dollies designed to make moving trailers with a ball hitch receiver type system easier. The first model, Force, comes in two (2) configurations, one capable of towing 5K (11,023 lbs.) and the other 10K (22,046 lbs.). Force 5K is a single axle tractor equipped with a 1.5 hp electric motor and has two speeds (low- 30 feet per minute, high- 60 feet per minute). The second configuration, Force 10K, is also a single axle trailer, it is equipped with a 1.5 hp electric motor and has two speeds (low- 30 feet per minute, high- 60 feet per minute). Both the Force 5K and 10K are controlled by a “T” handle connected to the front of the dolly. The second model, Carrier 13K, is a 6 wheeled, single axle electric trailer dolly. The Carrier is powered by a 1.7 hp electric engine and has two speeds (low- 30 feet per minute, high- 60 feet per minute). The carrier is wireless and is operated by way of a separate remote control. The third model, Transformer 15K, is a 6 wheeled, single axle electric trailer dolly. The Transformer is powered by a 3.7 hp electric motor and has two speeds (low- 30 feet per minute, high- 60 feet per minute). You state that all models are capable of using either a 2” or 2 5/16” ball hitch. In your submission, you ask whether the Force 10, Transformer 15k, and Carrier 13k, are classifiable in either heading 8427, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Fork-lift trucks; other works trucks fitted with lifting or handling equipment.” or heading 8428, which provides for “Other lifting, handling, loading or unloading machinery.” Based on the information in your submission, the dollies are not used to lift and handle trailers. Furthermore, Note 1(l) to Section XVI (which includes headings 8427 and 8428) excludes articles of Section XVII. As such, headings 8427 and 8428 are precluded from consideration. The applicable subheading for the Force 5K and 10K will be 8701.10.0100, HTSUS, which provides for “Tractors (other than tractors of heading 8709): Single axle tractors.” The general rate of duty will be Free. The applicable subheading for the Carrier 13K and Transformer 15K will be 8701.91.5000, HTSUS, which provides for “Tractors (other than tractors of heading 8709): Other, of an engine power: Not exceeding 18 kW: Other.” The general rate of duty will be Free. 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 Sullivan at matthew.sullivan@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division