N361157

N361157May 21, 2026CLA-2-84:OT:RR:N1 104 CATEGORY: Classification TARIFF NO.: 8479.89.9599 Jennifer DiazDiaz Trade Law, P.A.12700 Biscayne Blvd., Suite 401North Miami, FL 33181RE: The tariff classification of electric vessel fin stabilizer systems and a vessel steering system from ItalyDear Ms. Diaz:In your letter dated April 30, 2026 , you requested a tariff classification ruling on behalf of your client, CMCMarine Corp.The products in question are described as electric vessel fin stabilizer systems, models HS60, LR250, STAB25, and STAB 40, and an electric vessel steering system, model DIRECTA 120. These complete,electro-mechanical automatic systems employ motors, electronics, and other apparatus to stabilize or steerwater yachts.The HS and LR fin stabilizer systems consist of (1) hydrodynamic fins to stabilize a vessel; (2) an actuatorthat rotates the fins; (3) an inertial platform to feed a yacht’s movement data into an Electronic Control Unitpanel; (4) Electronic Power Unit panels which contain servos to feed the electric motors; (5) ElectronicControl Unit panel containing the CPU which reads all data and commands the actuators’ movement; and (6)a touchscreen control monitor. The actuator assembly consists of a brushless electric motor, gearbox, mainflange, motor encoder, fin encoder, lubrication port, and a tapered shaft. Unlike the HS and systems, theLRSTAB stabilizer systems are shaftless. They consist of (1) high hydrodynamic efficiency active fins; (2)actuators (with electrical motors and gearbox) for fin rotation; panels; (3) an Electronic Power Unit panel; (4) inertial platform; and (5) a touchscreen control monitor. The HS, LR, andElectronic Control Unit STAB stabilizer systems control the roll, pitch, and yaw of a vessel through rotational movements.The DIRECTA steering system consists of (1) two electric linear actuators, with each consisting of arecirculating ball screw actuator drive by a main motor, with most models being equipped with a backup gearmotor; (2) two electric motors; (3) control switchboard; (4) junction box; (5) Wheelhouse Control Stationproviding user interface to control the system by touchscreen, an encoder connected to the rudder wheel, andan interface to the autopilot system; (6) Flybridge Control Station with a rudder wheel, touchscreen, and anencoder connected to the rudder wheel; and (7) Wing Control Station which includes a touchscreen with buttons, rudder angle indicators, monitoring an alarm pages. The DIRECTA steering system controls thedirection of a vessel.In your submission, you suggest that the subject articles are correctly classified under heading 8501,Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric motors andgenerators (excluding generating sets):”. We disagree. The vessel stabilizer and steering systems do useelectric motors for the rotary motion required to turn the fins or rudders, but they also include othercomponents or equipment outside of heading 8501 to form a complete system. Consequently, the subjectarticles are precluded from classification within heading 8501.The applicable subheading for both the electric vessel fin stabilizer systems, models HS60, LR250, STAB 25,and STAB 40, and the electric vessel steering system, model DIRECTA 120, each imported together as acomplete system with the above-referenced components, will be 8479.89.9599, HTSUS, which provides for“Machines and mechanical appliances having individual functions, not specified or included elsewhere in thischapter; parts thereof: Other machines and mechanical appliances: Other: Other: Other.” The general rate ofduty will be 2.5 percent ad valorem.The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenienceand are subject to change. The text of the most recent HTSUS and the accompanying duty rates are providedat https://hts.usitc.gov/.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties 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 eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems 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 asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Arthur Purcell at arthur.purcell@cbp.dhs.gov. Sincerely, (for)James P. ForkanDirectorNational Commodity Specialist Division

set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Arthur Purcell at arthur.purcell@cbp.dhs.gov.
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division