N365188

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 N365188 October 9, 2026 CLA-2-84:OT:RR:NC:N1:104 CATEGORY: Classification TARIFF NO.: 8486.40.0020 Kyle Crouch Livingston International 917 Clarke Rd Martinsville, VA 24112 RE: The tariff classification of a solar panel assembly line from China Dear Mr. Crouch: In your letter dated September 17, 2026, you requested a tariff classification ruling on behalf of your client, Translucent Solar LLC (TSL). The imported products in question are various machines and equipment used in an integrated and largely interconnected assembly line for assembling heterojunction technology (HJT) photovoltaic (PV) solar cells into finished HJT solar panels (aka solar modules). The machinery and equipment will be used together to perform the connecting, assembling, laminating, testing, and finishing of the solar panels. You state that the goods will arrive in multiple ocean shipments and moved in-bond to a manufacturing Foreign-Trade Zone (FTZ) located in South Carolina. Once all equipment is in the FTZ is hooked up and ready to start production, TSL then will file a formal entry with CBP and pay all required duties and taxes. In your submission, you group the various machines and equipment into five (5) production or assembly zones, as follows. Zone 1 involves cell stringing, glass loading, and initial layup operations to create aligned modules stacks for interconnection and pre-lamination operations. The main components in this zone include automatic solar stringer layup machines used to automate the assembly of individual solar cells into strings, a gantry type layup machine to transfer with battery string out of the string welding machine to the layup machine, a glass loader, a module film scraping and melting machine (equipment that applies, repositions, or separates encapsulation films from PV modules), a foil cutter, buffer units (automated storage units that prevent assembly bottlenecks), and various conveyors. Zone 2 involves bussing, interconnection, and pre-lamination preparation to create an electrically connected, lamination-ready module stack. The zone’s main machinery includes a flipper machine, various conveyors, an auto strip (or edge trimming) application machine, a backsheet cutting and laying machine, a bussing machine, butyl rubber coating equipment, a double glass layup machine, a G-G edge sealing machine, a G-G rework gantry, glass loader, buffer units, lateral lifting transfer unit, and a lead flattening machine. Zone 3 involves the production of laminated PV module bodies for junction-box (J-Box) and framing operations. The main equipment in this zone includes laminators, an auto adhesive tape machine, buffer units, conveyors, and lifters. Zone 4 involves J-Box installation/welding, lead shaping, trimming, edge work, frame handling, glue, mounting and framing to produce a finished physical solar module ready for curing, electrical testing and final inspection. The principal equipment here includes automatic framing machines, an automatic trimming machine, an automatic edge peeling machine, an automatic J-Box installation machine, J-Box soldering machine, busbar lead shaping machine, frame handlers, frame gluing machine, a visual inspection flipper, robotic jig (mounting system) installation machine, buffer units, and various conveyors. Zone 5 involves curing, labeling, testing and sorting. This zone includes an automatic capping machine (to seal J-Boxes to solar panels), corner grinding and protector machines, a curing line and curing line handler, glue potting hander, module upender/tilter (handling machine), robotic jig removal machine, sorting machines, two-component glue machine, buffer units, and conveyors. Also employed in one or more of the five assembly zones are stand-alone testing or measuring equipment which fall under Chapter 90, Harmonized Tariff Schedule of the United States (HTSUS). This testing and inspection equipment includes electroluminescence (EL) testing machines and units, Hi-pot (high-potential) testing machine, solar IV testers, scanning AOI (automated optical inspection) tester, three-code verification machine, and the frame inspection machine. Other imported equipment appears to be of an auxiliary or supporting nature, without being essential to or materially contributory to the assembly function. This includes an automatic labeling machine and a barcode pasting machine (for application of labels), personnel ladders, and transfer trolleys. In your submission, you state that the machines and equipment described above are designed principally for production of solar panels. You assert that Note 4, Section XVI, HTSUS, applies in classifying all the Section XVI components of the proposed solar panel assembly line under heading 8486, HTSUS, as machines or apparatus of a kind used solely or principally for the assembly of semiconductor devices. Based on the available information, we conclude that Note 4 is applicable to much of, but not all of, the imported machinery and equipment. Section XVI, Note 4, HTSUS, provides that where a combination of machines, whether separate or interconnected by piping, by transmission devices, by electric cables or other devices, contribute together to a clearly defined function covered by one of the headings in Chapter 84 or Chapter 85, HTSUS, then the whole is classified in the heading appropriate to that function. The Explanatory Notes to Section XVI, (VII) Functional Units (Section Note 4), provides in part that “the expression ‘intended to contribute together to a clearly defined function’ covers only combinations of machines essential to the performance of the function specific to the functional unit as a whole, and this excludes machines or appliances fulfilling auxiliary functions and which do not contribute to the function of the whole.” All such components are machines, machine components, or appliances having functions that, when working together, directly contribute materially to a function that is clearly in a single HTSUS heading. We agree that most of the assembly machinery and equipment described above, with the exception of the referenced testing and inspection machinery of Chapter 90, HTSUS and equipment fulfilling auxiliary functions, constitutes a single functional unit for purposes of Note 4, Section XVI, whose clearly defined function is the assembly of PV solar panels. When entered into the United States as a complete solar panel production assembly line, the applicable subheading for the assembly machinery and equipment described above, other than the aforementioned testing, inspection, and auxiliary equipment, will be 8486.40.0020, HTSUS, which provides for “Machines and apparatus of a kind used solely or principally for the manufacture of semiconductor boules or wafers, semiconductor devices, electronic integrated circuits or flat panel displays; machines and apparatus specified in note 11(C) to this chapter; parts and accessories: Machines and apparatus specified in note 11(C) to this chapter: For assembling semiconductor devices or electronic integrated circuits.” The general rate of duty will be free. You state that the subject merchandise will be assembled and configured into a complete solar panel assembly line in a FTZ. This ruling is being issued solely to address the classification of the assembly line and makes no determination as to whether the merchandise has been entered properly into the FTZ. We recommend that your client seek advice from the CBP Headquarters Office of Regulations and Rulings. 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 addre

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 Arthur Purcell at arthur.purcell@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division