Haptic Motors for Car Safety Warning Systems Classifiable as Motors, not Car Parts, CBP Says

Haptic motors intended to be mounted to a vehicle seat for sending vibrating warning signals to the driver during certain safety conditions are classifiable as electric motors, rather than as signaling equipment for motor vehicles, CBP said in a ruling dated Oct. 18.

The issue came before CBP in a request for reconsideration of a New York ruling letter issued by the agency in 2018. CBP classified the haptic motors under subheading 8501.10.40 as “Electric motors and generators (excluding generator sets): Motors of an output not exceeding 37.5 W: Of under 18.65 W: Other: DC,” dutiable at 4.4%.

The haptic motors consist of a small brush rotary motor connected at the end of its shaft to an eccentric disk, which generates radial vibrations to the seat. The motor and disk are contained within a single plastic housing, so the entire assembly appears as a solid plastic block.

Nidec Automotive argued that court precedent requires that motors create “motive force” for classification in heading 8501, with a spindle that transmits energy created by the motor to the motor’s intended load. It said the eccentric disk counterweight does not assist the motor in creating motive force, so the haptic motor can’t be classified in the heading.

CBP disagreed. “Here, the haptic motor transmits mechanical energy from its electric motor to its intended load -- the eccentric disc counterweight,” CBP said. “While this intended load here is self-contained, rather than external, the transmission of mechanical energy to the eccentric disc counterweight is crucial to the device’s ultimate purpose.”

The Explanatory Note to heading 8501 also says that electric motors are machines for transforming electrical energy into mechanical power, including rotary motors, CBP said in the ruling, HQ H321766. “The haptic motor at-issue transforms input electrical energy into the rotation of the eccentric disk counterweight,” and so meets the requirements of the explanatory note, CBP said.

As the motor is classifiable in heading 8501, notes to Section XVI of the tariff schedule preclude classification in heading 8512, CBP said. Nor can it be classified as machines not classifiable elsewhere in the tariff schedule of heading 8479, the agency said, upholding its 2018 New York ruling.