RE: The tariff classification of an electric motor driven fire pump controller from Canada

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365234 October 20, 2026 CLA-2-90:OT:RR:NC:N1:105 CATEGORY: Classification TARIFF NO.: 9032.20.0000 Brooks Allen Skadden, Arps, Slate, Meagher & Flom LLP 1440 New York Avenue, N.W. Washington, DC 20005 RE: The tariff classification of an electric motor driven fire pump controller from Canada Dear Mr. Allen: In your letter dated September 19, 2026, on behalf of your client, Tornatech Inc., you requested a tariff classification ruling. Descriptive literature was provided for our review. The item under consideration is described as the Tornatech GPX Electric Motor Driven Fire Pump Controller, which is an industrial electric motor controller designed to automatically start and stop electric motor-driven fire pumps for the purpose of keeping the water lines pressurized. The central command and control unit is housed in a heavy-duty steel enclosure and features specialized internal electrical circuitry including a main disconnecting means, an overcurrent circuit breaker, motor contactors for alternating current (AC) motor starting (such as across-the-line or part-winding configurations), and a digital microprocessor control panel. The system is primarily designed to continuously monitor water pressure within the fire sprinkler piping via a built-in pressure transducer. Upon sensing a pressure drop, indicative of a fire emergency or leak, it automatically sequences the starting mechanism to energize the high-horsepower electric fire-pump motor. Once the leak or fire emergency has concluded and the pressure stabilizes, the GPX will turn off the pump and monitor the situation until there is another drop in pressure. It also integrates manual start/stop mechanisms, visual diagnostic displays, and alarm telemetry links. Chapter 90 Note 7 states: Instruments and apparatus for automatically controlling the flow, level, pressure or other variables of liquids or gases, or for automatically controlling temperature, whether or not their operation depends on an electrical phenomenon which varies according to the factor to be automatically controlled, which are designed to bring this factor to, and maintain it at, a desired value, stabilized against disturbances, by constantly or periodically measuring its actual value. The Tornatech FOX controller operates entirely based on an electrical phenomenon that varies directly with the physical factor to be controlled, namely, fluid pressure within the fire main loop. While the panel houses components found in heading 8537 (such as circuit breakers and motor starters), these components do not serve the independent purpose of general electrical distribution. Rather, they function entirely as the sub-components of an integrated machine whose principal function (per Section XVI Note 3, applicable to Chapter 90 via Note 3) is the automatic regulation of pressure. Additionally, the electric motor driven fire pump controller has all of the components necessary to meet Chapter 90 Note 7. This includes: A) the measuring device (a 0-500 PSI pressure transducer continuously sensing system side water pressure); B) the control device (ViZiTouch V2.1 embedded control logic, comparing measured pressure to field-adjustable cut-in/cut-out setpoints); and C) the operating device (model specific contactors/starters energizing or de-energizing the dedicated fire pump motor). Since the primary purpose of the controller meets the terms of Chapter 90 Note 7, Section XVI Note1(m) is applicable and the device cannot be classified in Chapter 85. Despite the remaining features of the device, such as the circuit breakers, surge arrestors, and alarms, the classification will remain in Chapter 90. Accordingly, the applicable subheading for the Tornatech GPX Electric Motor Driven Fire Pump Controller will be 9032.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Automatic regulating or controlling instruments and apparatus; parts and accessories thereof: Manostats.” 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division