Electric vehicle components are becoming increasingly complex, and so is their tariff classification. This case study looks at how U.S. Customs classified integrated electric drive motor assemblies (E-Axles) imported from Germany, and what importers can learn from it.
Overview of the Products
The classification request covered two electric drive motor assemblies, both designed for vehicle propulsion and incorporating multiple components into a single unit:
1. Beam E-Axle Electric Drive Motor Assembly
- 375 kW electric motor
- Integrated gearbox
- Integrated inverter
2. X83F E-Axle Electric Drive Motor Assembly
- 200 kW electric motor
- Integrated gearbox
- Integrated inverter
In both cases, the gearbox and inverter are physically incorporated into the motor assembly and are not imported as separate items.
How the Assemblies Function
Although each assembly contains several components, their roles are clearly defined:
- Electric motor: Generates rotational torque for vehicle propulsion
- Gearbox: Converts the motor’s rotational force into usable propulsion
- Inverter:
- Converts DC current to AC current for motor operation
- Controls motor performance
- Communicates with vehicle electrical systems
- Converts generated AC current back into DC to recharge batteries
While both DC and AC currents are involved, it is the converted AC current applied to the stator that ultimately produces the mechanical motion.
Classification Challenge: Single Machine or Multiple Machines?
From a customs perspective, the key question was whether these E-Axle assemblies should be classified as:
- A combination of multiple machines, or
- An electric motor with supporting apparatus
Customs determined that although the gearbox and inverter are essential for operation, they facilitate and support the electric motor, rather than changing its fundamental character.
This distinction is critical in tariff classification.
Final Tariff Classification Decision
Customs agreed with the importer’s position and applied Chapter 85, covering electric motors.
Beam E-Axle Electric Drive Motor Assembly
- HS / HTSUS Code: 8501.53.8060
- Description: Other AC motors, multi-phase, exceeding 75 kW
- Duty Rate: 2.8%
X83F E-Axle Electric Drive Motor Assembly
- HS / HTSUS Code: 8501.53.8040
- Description: Other AC motors, multi-phase, exceeding 75 kW but not exceeding 373 kW
- Duty Rate: 2.8%
Both products were classified based on output power, not on the presence of additional integrated components.
Key Takeaways for Importers
This ruling highlights several important customs principles:
- Integrated systems can still be classified as a single machine
- Supporting components do not necessarily change the tariff heading
- Output power is a critical factor for electric motor classification
- Accurate technical descriptions are essential for correct classification
Electric vehicle components, especially integrated systems like E-Axles, are high-risk products for misclassification if not properly analysed.
Why Customs Advice Matters
Classifying advanced electric drive systems requires a clear understanding of:
- Functional hierarchy
- Essential character
- Harmonized System interpretation rules
Seeking advice from an experienced customs agent or classification specialist can help avoid delays, reclassification, and unexpected duty costs.
👉 Read more real-world customs classification examples and expert guidance at
customsdirectory.com
❓ FAQ Section
How are integrated electric drive motors classified by customs?
Integrated electric drive motors are classified based on their primary function. When supporting components like gearboxes and inverters facilitate the motor’s operation, the product is classified as an electric motor.
Does an inverter change the HS code of an electric motor?
No. When the inverter is physically integrated and supports motor operation, it does not change the tariff classification of the electric motor.
Why are E-Axle motor assemblies classified as electric motors?
Customs authorities consider the electric motor to provide the essential character, with other components serving supportive functions.
What HS codes apply to high-power electric motors?
High-power, multi-phase AC electric motors exceeding 75 kW are classified under heading 8501, with subheadings based on output power.
Why is professional customs advice important for EV components?
Electric vehicle components are complex and high-risk for misclassification. Advice from a customs agent helps ensure correct HS codes, duty accuracy, and compliance.
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