The tariff classification of a parts kit from China

N362150 June 26, 2026 CLA-2-84:OT:RR:NC:N1:103 CATEGORY: Classification TARIFF NO.: 8431.20.0000 Adrianne Barkley Terra Worldwide Logistics LLC 1400 Hembree Rd. Roswell, GA 30076 RE: The tariff classification of a parts kit from China Dear Ms. Barkley: In your letter dated June 8, 2026, you requested a tariff classification ruling on behalf of your client, East West Manufacturing LLC. The merchandise under consideration is a kit containing components for the Hercules H-DU lift bot, an automated lifting robot used in Amazon fulfillment centers to lift and transport products. The kit contains four components: an H-DU Linkage Kit Rotary (part number 400-01256), an H-DU Rear Chassis Subassembly (part number 400-02390), an H-DU Panhard Left Assembly (part number 400-01281), and an H-DU Panhard Right Assembly (part number 400-01282). These components can be separated and stored as inventory, sold individually, or sold together as a kit. The H-DU Linkage Kit Rotary is a subassembly for the inner lifting mechanism of the lifting robot and is composed of aluminum castings and steel shafts with plastic bushings. This assembly is driven by an electric motor and used to raise a lifting plate. The motor, gears, and electrical components are not imported with the subassembly. The H-DU Rear Chassis Subassembly forms the lower structure of the robot and is a die-cast aluminum frame with plastic bushings. It has a semi-circular profile and features mounting points, cutouts, and notches throughout its body. The H-DU Panhard Left Assembly and H-DU Panhard Right Assembly are left and right aluminum linkage components for the inner lifting mechanism. They resemble elongated, rod-like components with mounting points at each end. In your submission, you asked if the merchandise can be treated as a kit or set. According to General Rule of Interpretation (GRI) 3(b), a set must: (a) consist of at least two different articles which are, prima facie, classifiable in different headings; (b) consist of products or articles put up together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to end users without repacking. Since all four components are classified in the same heading, may be sold individually, and are designed to be replaced separately on the lifting robot, they do not meet the requirements for a set. Therefore, each item is classified separately. The applicable subheading for the H-DU Linkage Kit Rotary, H-DU Rear Chassis Subassembly, H-DU Panhard Left Assembly, and H-DU Panhard Right Assembly will be 8431.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts suitable for use solely or principally with the machinery of headings 8425 to 8430: Of machinery of heading 8427.” The general 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 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 Paul Huang at paul.huang@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division