The tariff classification of a lift and an automated mobile robot from Israel

N362547 July 15, 2026 CLA-2-84:OT:RR:NC:N1:103 CATEGORY: Classification TARIFF NO.: 8428.90.0390; 8427.10.8050 Gail Cumins Sharretts Paley Carter & Blauvelt PC 75 Broad Street New York, NY 10004 RE: The tariff classification of a lift and an automated mobile robot from Israel Dear Ms. Cumins: In your letter dated June 24, 2026, you requested a tariff classification ruling on behalf of your client, Five Points Development Group. The merchandise under consideration is referred to as an automated storage system that consists of an automated mobile robot, a vertical lift, an electrical cabinet, a communications cabinet, a charger, and aluminum storage boxes. The components of the system are not confined to a single structural frame, common base, or common housing, but are installed throughout a residential building on different floors and in separate areas. For example, the lift may be installed in a dedicated lobby area while the robots are located elsewhere in the building. The lift is incorporated into a building’s infrastructure and is used to raise and lower pallets between floors. This lift consists of a moving platform affixed to rails on a vertical frame, which is equipped with a gearmotor, a counterweight, sprockets, chains, and various sensors. The lift measures 2,400 millimeters in length, 2,000 millimeters in width, 1,500 millimeters in height, and has a 3,000-kilogram lifting capacity. The automated mobile robot is designed to lift and transport a flat pallet in industrial or commercial environments. It has a square metal chassis that contains eight electric motors, a lithium-ion battery, and a screw jack drive unit. The drive unit actuates the vehicle’s lifting mechanism, which consists of four screw jacks, each with a 60-millimeter lifting stroke. The robot measures approximately 1,700 millimeters in length, 1,700 millimeters in width, 260 millimeters in height, and has a 1,000-kilogram lifting capacity. In your submission, you suggest that the components, when imported in a single shipment, are classified as a functional unit pursuant to Section XVI, Note 4 under heading 8428 of the Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other lifting, handling, loading or unloading machinery (for example, elevators, escalators, conveyors, teleferics).” We disagree. As noted above, the various machines and systems are distributed across different floors and throughout the building, and the automated guided robots are free-roaming independent machines. We do not find that the separate components perform a single, clearly defined function described by heading 8428. Rather, the various machines serve multiple, distinct purposes or fulfill auxiliary functions. Therefore, they are classified separately. The applicable subheading for the lift will be 8428.90.0390, HTSUS, which provides for “Other lifting, handling, loading or unloading machinery (for example, elevators, escalators, conveyors, teleferics): Other machinery: Other.” The general rate of duty will be free. The applicable subheading for the automated guided robot will be 8427.10.8050, HTSUS, which provides for “Fork-lift trucks; other works trucks fitted with lifting or handling equipment: Self-propelled trucks powered by an electric motor: Other: Automated guided vehicle (AGV): Other.” The general rate of duty will be free. There is insufficient information to classify the aluminum storage boxes, charger, and electrical cabinet. Specific details were not provided. As per our meeting on July 1, 2026, these items will need to be addressed separately. 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