N359941

N359941 April 20, 2026 CLA-2-85:OT:RR:NC:N2 207 CATEGORY: Classification TARIFF NO.: 8501.31.2000; 8543.90.8885 Robert Scott Curtiss-Wright Controls Integrated Sensing, Inc. 1100 W Grove Pkwy, Ste 102 Tempe, AZ 85283 RE: The tariff classification of components for motors and sensors from various countries Dear Mr. Scott: In your letter dated March 22, 2026, you requested a tariff classification ruling. There are three items at issue with this request, which are all identified as components for motors or sensors incorporated into a thermal management system within an aircraft. Each item is identified by part numbers H448B Motor/RVDT/Gearhead, 1075-608-016 RVDT Core Assembly, and 1140-608-016 Secondary Core. The H448B Motor/RVDT/Gearhead is comprised of a stepper motor, rotary variable differential transformer (RVDT), and gearhead. The stepper motor is a DC type brushless motor with a maximum power output of 38 Watts. The RVDT is a rotary position sensor and the gearhead is incorporated to modify the speed/torque of the motor. The component uses electromagnetic principles to convert electrical power into mechanical power, which is transferred through the mechanical gear transmission to the output of the rotary actuator to interface with the butterfly valve in an aircraft’s thermal management system. You state that this component originates from Mexico. The 1075-608-016 RVDT Core Assembly is a part of the RVDT position feedback sensor for the correct operation of the aircraft system valves. It is the stator for the RVDT position transducer. An electromagnetic field is created in the excitation windings and measured in the differential windings as a function of the rotor position. You state that this component originates from Costa Rica. The 1140-608-016 Secondary Core is a machined part of a core assembly of an RVDT rotary position sensor. It is used to enable position measurement by carrying the electromagnetic flux created by the excitation windings to the differential windings, allowing the voltage differential to be measured and infer precise position. You state that this component originates from Canada. In your request, you suggest that the H448B Motor/RVDT/Gearhead is correctly classified under subheading 8501.31.2000, Harmonized Tariff Schedule of the United States (HTSUS). You further suggest that 1075-608-016 RVDT Core Assembly and 1140-608-016 Secondary Core are correctly classified under subheading 8543.90.8885, HTSUS. We agree. The applicable subheading for the H448B Motor/RVDT/Gearhead will be 8501.31.2000, HTSUS, which provides for “Electric motors…: Other DC motors; DC generators: Of an output not exceeding 750 W: Motors: Exceeding 37.5 W but not exceeding 74.6 W”. The general rate of duty will be 2.8 percent ad valorem. The applicable subheading for the 1075-608-016 RVDT Core Assembly and 1140-608-016 Secondary Core will be 8543.90.8885, HTSUS, which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Parts: Other: Other: Other: 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 Howard Suh at howard.suh@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division

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 Howard Suh at howard.suh@cbp.dhs.gov. 
Sincerely,
 (for) James P. Forkan Director National Commodity Specialist Division