N357964

N357964 February 4, 2026 CLA-2-90:OT:RR:NC:N1:105 CATEGORY: Classification TARIFF NO.: 9031.80.8085 Cole Paterson Boron Energy Corp. 321-8188 Manitoba Street Vancouver, BC V5X0L5 Canada RE: The tariff classification, country of origin, and eligibility under the United States-Mexico-Canada Agreement (USMCA) of a dynamometer Dear Mr. Paterson: In your letter dated January 20, 2026, you requested a ruling on the tariff classification, country of origin for marking purposes, and USMCA eligibility of a dynamometer. The item under consideration is an electric motor dynamometer, which is a specialized testing apparatus designed for the development and evaluation of e-bike mid-drive units (motor, gearbox, and motor controller assembly). The device simulates the forces and resistances encountered during actual riding to enable engineers to assess performance characteristics without extensive road testing. This system is precisely configured with two internal permanent magnet test motors, each coupled to planetary gearboxes. These gearboxes are connected via flexible shaft couplings to two torque transducers, which in turn attach to the device under test (DUT), an e-bike mid-drive unit. One motor replicates human pedaling input, while the second motor provides the load, mimicking hills or headwinds. All components are mounted on a shared extruded aluminum base, secured to a table, and are controlled by dedicated motor controllers (inverters) that manage speed and torque. The motors and DUT share a common electrical connection for power sharing, supplied by a single power supply and protected by fuses and contactors. Additional fans provide cooling for the DUT and motors, and a polycarbonate cover ensures safety over the DUT. The DUT is supported by custom aluminum blocks and bearing housings, with the dynamometer arriving pre-assembled and bolted together for completion upon import. Integrated sensors measure crucial parameters such as torque output, motor speed, power consumption, and efficiency, allowing manufacturers to refine motor design, optimize control algorithms, and verify that the mid-drive unit meets performance and durability standards. Sensors include thermocouples, torque transducers (strain gauges), rotational speed sensors (encoders), voltage sensing (precision resistor divider), and a current sensor (hall-effect based non-contact sensor). Additional internal sensors exist in the motor (resolver, thermistor) and the controller (hall-effect based non-contact sensor, thermistor). The device will measure torque in Newton-Meters (Nm), rotational speed in Rotations Per Minutes (RPM), temperature in degrees Celsius, power in Watts (W), voltage in volts (V), and current in Amps (A). The electric motor dynamometer is a product of extensive global collaboration, with its components sourced from a diverse range of countries including China, the United States, India, Sweden, Canada, Taiwan, Japan, South Korea, Italy, Malaysia, Germany, Mexico, Austria, Hungary, Belgium, France, the Philippines, Poland, and Switzerland. Key components originating from China include transducers, the planetary gearbox, table, DUT holder block, bearing holders, fasteners such as nuts and bolts, the DUT output shaft, power supply, a 50A contactor, fuses, connectors, crimps and crimp tools, and the breakout board. The United States contributes essential parts like spiders for couplings, shaft couplings, 10 mm keys, raw material for the polycarbonate enclosure, nylon strapping, bolts, protection guard doublers, polycarbonate adhesive, fasteners, L brackets, washers, vibration dampers, a board, and a portion of the wiring. Taiwan supplies nuts, bolts, the E-stop button, inverter fans, motor fans, the resistor divider, and various wiring harnesses. India is the source for the Data Acquisition (DAQ) expander and the motors themselves. Germany provides aluminum extrusion, relays, splices, and capacitors, while Canada supplies foam insulation. Italy contributes bolts, and bearings are sourced from either Japan or South Korea. The motor controller is procured from Sweden. Malaysia supplies the amplifier, plugs, receptacles, and crimps. Mexico provides bars, resistors, shunts, and connectors. Additionally, various other small components are sourced from Japan, Belgium, France, the Philippines, Poland, and Switzerland. The dynamometer assembly process, conducted in Canada, comprises approximately twenty-six distinct steps. It commences with the connection of the gearbox and motors to the drive shaft using nuts and bolts, followed by the assembly of the Device Under Test (DUT) enclosure. Subsequently, torque transducers are secured, holes are drilled into the prep support table, and the bearing support is fabricated by pressing the bearing and datum pin into place. The DUT output shaft is then installed onto its support, datum pins are pressed into the DUT holder block, and the DUT support block is affixed to the dynamometer base plate. The process continues with the assembly of the bearing support to the DUT support, the installation of keys onto the DUT output shafts, and the attachment of the coupling to the DUT output shafts. Two keys are then installed onto the torque transducer before it is mounted to the gearbox coupling. Next, the motor and gearbox assembly is integrated by sliding it into the extruded base and securing it with fasteners. This is followed by mounting the motor controllers for heatsinking and the precise cutting and crimping of terminals and wires. The fan is then installed onto the DUT enclosure, which is subsequently mounted onto the base. The final stages involve the installation of the high-current bus distribution bar, fastening the entire assembly to the table with bolts, installing the power supply and DAQ system, and completing the wire harness assembly and routing to achieve full functionality. In your letter, you suggest the applicable subheading of the electric motor dynamometer to be 9031.80.8070, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Measuring or checking instruments, appliances and machines, not specified or included elsewhere in this chapter; profile projectors; parts and accessories thereof: Other instruments, appliances and machines: Other: Equipment for testing the characteristics of internal combustion engines: Other.” We disagree. Since the device that is to be tested by the dynamometer is a mid-drive electric motor and not an internal combustion engine, classification under subheading 9031.80.8070, HTSUS, is excluded. Accordingly, the applicable subheading for the electric motor dynamometer will be 9031.80.8085, HTSUS, which provides for “Measuring or checking instruments, appliances and machines, not specified or included elsewhere in this chapter; profile projectors; parts and accessories thereof: Other instruments, appliances and machines: Other: Other.” The general rate of duty will be free. COUNTRY OF ORIGIN Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country

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) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division