In ruling N326460 (June 23, 2022), Customs and Border Protection (CBP) discussed the tariff classification of a robotic vacuum cleaner from China. The product is identified as the YEEDI Model DVX46, K850+ (the “K850+”). The K850+ is round in shape, measuring approximately 508 mm in diameter and 474 mm in height. The model is rated 40W with a dust bin capacity of 300 ml. Designed for domestic use only, the K850+ suctions up debris with a side brush while the main brush rotates to sweep the dust to the suction port from both sides. Then, the washable mopping pads “mop” the floor to complete the floor cleaning process.

The suction occurs by means of a turbine fixed directly onto the shaft of the motor turning at high velocity. The dust and other materials are collected in an internal or external dust bag/receptacle, whereas the air suctioned in and filtered is also used to cool the K850+’s motor. After the floor cleaning process is completed, the robot returns to the Self-Cleaning Station via a corresponding interface to perform a self-cleaning procedure. The Self-Cleaning Station is designed to collect dust, clean mopping pads, dry mopping pads, refill the water tank, and charge the robot.

CBP determined that the tariff classification of the K850+ would be 8508.11.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Vacuum cleaners, parts thereof: With a self-contained electric motor: Of a power not exceeding 1,500 W and having a dust bag or other receptacle capacity not exceeding 20 l”.  The rate of duty is free.

Additionally, pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, Chinese products under subheadings 8508.11.0000, HTSUS, unless specifically excluded, are subject to an additional 25% ad valorem duty rate. As such, the chapter subheading 9903.88.03 must be reported in addition to subheading 8508.11.0000, HTSUS.

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Photo of Frances P. Hadfield Frances P. Hadfield

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving…

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving customs compliance, audits, customs enforcement, as well as import penalties.

Frances represents clients before the U.S. Court of International Trade and the U.S. Court of Appeals for the Federal Circuit, as well as in proceedings at the administrative level. She advises corporations on both substantive federal and state regulatory issues that involve U.S. Customs and Border Protection, the Federal Trade Commission, Food and Drug Administration, and U.S. Fish & Wildlife in matters pertaining to product admissibility, audits, classification, import restrictions, investigations, marking, licenses, origin, penalties, and tariff preference programs.

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Photo of Martín Yerovi Martín Yerovi

Martín Yerovi is an international trade analyst in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border Protection…

Martín Yerovi is an international trade analyst in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border Protection (CBP). He works closely with attorneys developing courses of action for clients impacted by investigations under Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962. He also supports unfair trade investigations, including antidumping (AD) and countervailing duty (CVD) investigations, sunset reviews, and changed circumstance reviews before the Department of Commerce and the International Trade Commission (ITC).

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