HazHandler; Remote Controlled Multi-Task Vehicle; Works Truck Fitted With Lifting or Handling Equipment, Heading 8427; Front End Bucket Loader, Heading 8429; Wheeled Vehicle With Skid Steer Loader Attachments; Principal Function, Section XVI, Note 3; HQ 088585, HSC Document 37.380 E Annex M/20 Dear Ms. Campanian:
Revoked· CBP ruling HQ 955547· Issued 1994-03-24
Ruling text
HQ 955547
MARCH 24 1994
CLA-2:CO:R:C:M 955547 JAS
CATEGORY: Classification
TARIFF NO.: 8429.51.10, HTSUS
Ms. Linda Campanian
Milne & Craighead Customs Brokers (USA), Inc.
P.O. Box 2
Sweetgrass, MT 59484
RE: HazHandler; Remote Controlled Multi-Task Vehicle; Works
Truck Fitted With Lifting or Handling Equipment, Heading
8427; Front End Bucket Loader, Heading 8429; Wheeled Vehicle
With Skid Steer Loader Attachments; Principal Function,
Section XVI, Note 3; HQ 088585, HSC Document 37.380 E Annex
M/20
Dear Ms. Campanian:
Your letter to the Area Director of Customs, New York
Seaport, dated December 2, 1993, on behalf of Robotech Industries
Ltd., has been forwarded to this office for reply. Your inquiry
concerns the tariff classification of the HazHandler remote
controlled multi-task vehicle from Canada. A brochure was
submitted.
FACTS:
The vehicle in issue is four-wheeled apparatus measuring 131
in. x 60 in. x 58 in. It is remote controlled by means of a
shoulder harness mounted command unit, all vehicle and attachment
motions being controlled from two dual axis, self centering
joysticks. It has no space for a driver. The HazHandler is
powered by a 4-cylinder, 40 hp. diesel engine with a modified
Bobcat 753 skid steer loader chassis and powertrain, and has a
hydraulic lifting system that is integral with the structure of
the machine. It is equipped with flotation tires and weighs
4,300 lbs. with a 1,300 lb. payload capacity. The HazHandler
works a variety of standard skid steer loader attachments to
load, dump, bulldoze, auger, grapple, and sweep. Specialty tools
are also available such as mechanical arms, drum and barrel
handling attachments, and dry chemical or foam fire fighting
apparatus. The Hazhandler is suitable for use in spaces too
small for manned works trucks and is advertised for hazardous - 2 -
tasks in rough terrain as it has a TV vision system to include 5
in. color screen and camera with zoom lens.
The provisions under consideration are as follows:
8427 [o]ther works trucks fitted with lifting
or handling equipment:
8427.27.20 Other self-propelled trucks:
8427.20.80 Other...Free
* * * * *
8429 Self-propelled bulldozers, angledozers,
graders, levelers, scrapers, mechanical
shovels, excavators, shovel loaders, tamping
machines and road rollers:
8429.51 Front-end shovel loaders:
8429.51.10 Wheel-type...2 percent
ISSUE:
Whether the HazHandler has a principal function.
LAW AND ANALYSIS:
Merchandise is classifiable under the Harmonized Tariff
Schedule of the United States (HTSUS) in accordance with the
General Rules of Interpretation (GRIs). GRI 1 states in part
that for legal purposes, classification shall be determined
according to the terms of the headings and any relative section
or chapter notes.
The Harmonized Commodity Description And Coding System
Explanatory Notes (ENs) constitute the Customs Cooperation
Council's official interpretation of the Harmonized System.
While not legally binding on the contracting parties, and
therefore not dispositive, the ENs provide a commentary on the
scope of each heading of the Harmonized System and are thus
useful in ascertaining the classification of merchandise under
the System. Customs believes the notes should always be
consulted. See T.D. 89-80.
Heading 8427 by its terms specifically delineates works
trucks fitted with lifting or handling equipment. The ENs at p.
1202 state that self-propelled shovel loaders of heading 8429 are
wheeled or crawler machines with a front-mounted bucket which
pick up material through motion of the machine, transport and - 3 -
discharge it. The HazHandler performs functions that are
described in both headings.
As stated in HQ 088585, dated May 2, 1991, on skid steer
loaders similar to the vehicle in issue here, where headings 8427
and 8429 are in competition Section XVI, Note 3, HTSUS, must be
applied. This note states in part that machines adapted for the
purpose of performing two or more complementary or alternative
functions are to be classified as if consisting only of that
component or as being that machine which performs the principal
function.
The submitted brochure contains six (6) pictures of the
HazHandler in action, three (3) of which show a bucket attachment
and one (1) a shovel attachment. The previously-cited ENs
indicate that self-propelled "shovel" loaders have a front-
mounted "bucket." In addition, the length and width measurements
include the bucket. From the available information, it is
apparent that the HazHandler is advertized and marketed as a
front end shovel loader. We find this to be their principal
function. HQ 088585, at p. 3. In addition, at its 9th. Session,
the Harmonized System Committee (HSC) ruled in Document 37.380 E
Annex M/20, that Bobcat self-propelled front loaders with 4-wheel
drive and skid steer, capable of being fitted with other
interchangeable tools, similar in all respects to the vehicles
here, were front-end shovel loaders of heading 8429.
HOLDING:
Under the authority of GRI 1, the HazHandler remote
controlled multi-task vehicle is provided for in heading 8429.
It is classifiable as a wheel-type front-end shovel loader in
subheading 8429.51.10, HTSUS.
Sincerely,
John Durant, Director
Commercial Rulings Division
Source: rulings.cbp.gov — ruling 955547, retrieved 2026-10-12T05:28:52Z, republished verbatim. This digest is informational; only CBP issues binding rulings.