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RE: The tariff classification of a Loadout System and an Automation System 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 N365016 September 22, 2026 CLA-2-84:OT:RR:NC:N1:103 CATEGORY: Classification TARIFF NO.: 8428.90.0390; 8537.10.9160 Maureen Celner Welke Customs Brokers USA, Inc. 36 Delaware St. Tonawanda, NY 14150 RE: The tariff classification of a Loadout System and an Automation System from Canada Dear Ms. Celner: In your letter dated September 11, 2026, you requested a tariff classification ruling on behalf of your client, Camar Mill Systems Ltd. The first item under consideration is referred to as a Loadout System, designed for loading animal feed into specialized trailers. As an integrated overhead assembly suspended above the loadout area in a feed mill, it consists of two belt-type collecting conveyors, a traveling shuttle conveyor, a trolley beam, and a sampler with a collection hopper. The collecting conveyors are located in the upper portion of the unit and positioned directly below loadout bins containing animal feed. These conveyors transport the material to the shuttle located at the center of the assembly. The shuttle travels along the trolley beam, depositing the animal feed into compartments in the trailer parked beneath. Mounted between the collecting conveyors and the shuttle conveyor, the sampler is an automated device that collects samples for quality control. All components described above will be imported in a single shipment. In accordance with Note 4 to Section XVI, Harmonized Tariff Schedule of the United States (HTSUS), we consider the subject Loadout System, with all of its interconnected components, to be a functional unit. The clearly defined function is loading animal feed. The second item under consideration is referred to as the Camar Progressor Automation System and is described as a system that controls feed mill operations, such as ingredient receiving, loading of finished animal feed, and other similar tasks. Its main components include a main programmable logic controller (PLC) control panel, a server station, secondary PLC control panels, human-machine interface (HMI) stations, an explosion-proof scanner panel, and a scale kiosk panel. The main PLC control panel is described as a dust-tight enclosure housing an industrial computer, input/output cards, networking equipment, Ethernet switches, power supplies, battery backup units, Ethernet cables, circuit breakers, and scale instruments, all mounted to a backplate via DIN rails. The secondary PLC control panels are similar, functioning as extensions of the main PLC and may be specially designed for explosive environments. The server station includes an industrial PC, power supply, battery backup, EtherCAT networking equipment, Ethernet switches, firewalls, and remote access hardware. The Camar system uses two types of HMI stations, those with integrated touch screens and those with external monitors, depending on the installation environment. The scanner panel is used for barcode scanning. These components are interconnected, as well as connected to auxiliary sensors and other electrical devices. All components described above will be imported in a single shipment. The applicable subheading for the Loadout System 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 Camar Progressor Automation System will be 8537.10.9160, HTSUS, which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity, including those incorporating instruments or apparatus of chapter 90, and numerical control apparatus, other than switching apparatus of heading 8517: For a voltage not exceeding 1,000 V: Other: Other: Other: Programmable controllers.” The general rate of duty will be 2.7 percent ad valorem. Merchandise is to be classified according to its condition as imported. Should the requirements of 19 CFR § 141.51 and 19 CFR § 141.58 not be met, each component of the system would be separately classified in its own respective heading 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 Paul Huang at paul.huang@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 Paul Huang at paul.huang@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division