HS Code Classification Guide:
Chapter 84 vs Chapter 85
Master the Critical Distinction Between Machinery and Electrical Equipment
Why Chapter 84 vs 85 Classification Matters
One of the most common—and costly—mistakes in customs classification occurs when determining whether a product belongs in HS Chapter 84 (Nuclear reactors, boilers, machinery and mechanical appliances) or Chapter 85 (Electrical machinery and equipment and parts thereof).
The difference isn’t merely academic. Misclassification between these chapters can result in:
- Import duty differences ranging from 0% to 25%+ depending on country and product
- Customs penalties for incorrect declarations ($5,000-$10,000+ per violation)
- Shipment delays and additional examination fees
- Loss of preferential trade agreement benefits
- Compliance issues affecting future imports
This comprehensive guide presents 20 detailed case studies demonstrating the practical application of classification rules, helping you understand the nuanced differences between these critical chapters.
Nuclear Reactors, Boilers, Machinery and Mechanical Appliances
Core Principle: Chapter 84 covers machinery where the primary function is mechanical action—converting energy into mechanical work through moving parts, rotation, compression, or physical force.
Key Characteristics:
- Mechanical energy conversion (motors, engines, pumps)
- Physical transformation (cutting, shaping, compressing)
- Heat generation or transfer (boilers, heat exchangers)
- Fluid movement (pumps, compressors, fans)
- Mechanical computing or control systems
- Industrial processing machinery
Electrical Machinery and Equipment and Parts Thereof
Core Principle: Chapter 85 covers apparatus where the primary function involves electrical or electronic processes—generating, converting, transmitting, storing, or utilizing electrical energy or signals.
Key Characteristics:
- Electrical energy generation (generators, solar cells)
- Electrical signal transmission (telecommunications)
- Electronic data processing (computers, controllers)
- Electrical energy conversion (transformers, converters)
- Audio/visual reproduction (speakers, displays)
- Electronic sensing and measurement
Critical Classification Criteria
| Classification Factor | Chapter 84 (Mechanical) | Chapter 85 (Electrical) |
|---|---|---|
| Primary Function | Mechanical work, physical transformation | Electrical/electronic signal processing |
| Energy Type | Mechanical energy dominant | Electrical energy or signals dominant |
| Motor/Engine Role | Motor IS the product (or integral to mechanical function) | Motor is auxiliary (supports electronic function) |
| Control System | Mechanical or electromechanical controls | Electronic controls and microprocessors |
| Output | Physical movement, heat, pressure, flow | Electrical signals, data, images, sound |
| Typical Duty Rates (USA) | 0% – 4.7% (most machinery) | 0% – 6% (electronics vary widely) |
🔍 Quick Classification Decision Tree
20 Classification Case Studies: Chapter 84 vs 85
Each case study demonstrates real-world classification scenarios with detailed reasoning and duty implications
Electric Water Pump (Centrifugal)
A centrifugal water pump with an integrated electric motor designed for residential water supply systems. The motor drives an impeller that creates centrifugal force to move water.
Centrifugal pumps, submersible
Why Chapter 84: The primary function is mechanical—moving water through centrifugal force. The electric motor merely provides power for the mechanical pump action. The product’s essential character is the pumping mechanism, not electrical processing. Per GRI 1, classify by essential character.
Desktop Computer
A complete desktop computer system including CPU, motherboard, RAM, storage, and power supply. Processes data electronically through microprocessors and integrated circuits.
Portable automatic data processing machines
Why Chapter 85: The primary function is electronic data processing through microprocessors and digital circuits. While it contains cooling fans (mechanical), these are auxiliary to the essential electronic function. The product cannot perform its intended purpose without electronic components.
Pneumatic Drill (Electric-Powered)
A handheld drilling machine with an electric motor that drives a rotary chuck through mechanical gearing. Used for drilling holes in various materials through rotational mechanical force.
Drills of all kinds, electro-mechanical
Why Chapter 84: Despite being electrically powered, the essential function is mechanical drilling through rotational force. The electric motor converts electrical energy to mechanical rotation, but the product’s purpose is physical material removal through mechanical action. Tools are classified by their mechanical working principle.
LED Display Screen (Advertising)
A large outdoor LED video display panel used for advertising, consisting of thousands of LED modules controlled by electronic circuitry to display images and video content.
Other monitors, color
Why Chapter 85: The primary function is electronic display of visual information. While individual LEDs convert electricity to light (could be argued as electrical apparatus), the assembled display panel’s purpose is video/image reproduction controlled by electronic circuits. Chapter 85 specifically covers display apparatus.
Industrial Air Compressor
A reciprocating air compressor with electric motor, designed to compress atmospheric air to high pressure for industrial applications. Features mechanical pistons and valves.
Reciprocating compressors, single-stage
Why Chapter 84: The essential function is mechanical compression of air through piston movement. The electric motor drives the mechanical compression mechanism. The product’s character is defined by its mechanical air-handling capability, not by its electrical power source. Chapter 84 specifically covers air/gas pumps and compressors.
Smartphone
A mobile telephone with integrated computing capabilities, touchscreen, cameras, wireless communication modules, and application processing abilities.
Smartphones
Why Chapter 85: Multiple electronic functions (telecommunications, computing, imaging) are processed through electronic circuitry. Every primary function relies on electronic signal processing and data transmission. Chapter 85 specifically covers telephone apparatus and data transmission equipment.
Electric Fan (Household)
A pedestal fan with electric motor driving rotating blades to create airflow for cooling purposes. Includes mechanical oscillation mechanism and speed controls.
Table, floor, wall, window or ceiling fans
Why Chapter 84: The primary function is mechanical air movement through rotating blades. While electrically powered, the essential character is the mechanical action of moving air. Note 2 to Chapter 85 explicitly excludes fans from that chapter. Fans are specifically provided for in Chapter 84.
Digital Camera
A digital still camera capturing images through electronic image sensors, processing them via digital circuitry, and storing them on electronic memory cards.
Digital still image video cameras
Why Chapter 85: The entire imaging process is electronic: light conversion to electrical signals via sensors, electronic image processing, digital storage. Though the lens system is mechanical, the essential character is electronic image capture and processing. Chapter 85 specifically covers television cameras and digital cameras.
Washing Machine (Automatic)
A front-loading automatic washing machine with drum, water pumps, heating element, and electronic control panel. Performs mechanical washing action through drum rotation and water circulation.
Automatic washing machines, household
Why Chapter 84: Despite electronic controls, the essential function is mechanical washing through drum rotation, water agitation, and mechanical action. The electronic control system is auxiliary to the primary mechanical washing process. Chapter 84 specifically covers washing machinery and household appliances based on mechanical principles.
Solar Panel (Photovoltaic)
A photovoltaic module containing solar cells that convert sunlight directly into electrical energy through the photovoltaic effect, producing DC electricity.
Photosensitive semiconductor devices, solar cells
Why Chapter 85: The primary function is electrical energy generation through semiconductor photovoltaic effect. There is no mechanical action involved—purely electrical conversion of light to electricity at atomic level. Chapter 85 specifically covers photosensitive semiconductor devices including solar cells.
Industrial Robot Arm
A multi-axis industrial robot with electric servo motors, mechanical joints, and programmable electronic controller for automated manufacturing tasks like welding, assembly, and material handling.
Industrial robots
Why Chapter 84: The essential character is mechanical manipulation and positioning in 3D space for performing mechanical work. While electronic control is sophisticated, the robot’s purpose is mechanical task performance. Note: If sold as a “controller unit” only without mechanical components, it could be Chapter 85. Complete robot systems are Chapter 84.
Bluetooth Speaker
A portable wireless speaker system with Bluetooth receiver, digital-to-analog converter, amplifier circuits, and speaker drivers for audio reproduction.
Single loudspeakers mounted in enclosures
Why Chapter 85: The primary function is electronic audio signal reception, processing, and reproduction. While the speaker cone moves mechanically, this mechanical movement is secondary to the electronic signal processing. The product’s essential character is as audio reproduction equipment. Chapter 85 specifically covers loudspeakers and audio equipment.
CNC Milling Machine
A computer numerical control (CNC) milling machine with spindle, cutting tools, motorized axes, and integrated computer control system for precision metal cutting and shaping.
Milling machines, numerically controlled
Why Chapter 84: Despite sophisticated computer control (CNC), the essential function is mechanical material removal through cutting. The machine performs mechanical work on physical materials. Electronic controls enhance precision but don’t change the fundamental mechanical nature. Machine tools are classified in Chapter 84 based on their mechanical working principle.
Wi-Fi Router
A wireless network router that receives, processes, and transmits digital data packets between devices and the internet using radio frequency signals and network protocols.
Machines for reception, conversion and transmission
Why Chapter 85: The primary function is electronic data transmission and network communication. All processes involve electronic signal reception, digital processing, and wireless transmission. There is no mechanical function. Chapter 85 specifically covers telecommunications equipment and apparatus for transmission of data.
Electric Forklift
A battery-powered electric forklift with electric drive motors, hydraulic lifting system, and electronic controls for material handling in warehouses.
Electric forklifts, other
Why Chapter 84: The essential function is mechanical lifting and transport of materials. Electric motors provide motive power, but the product’s character is mechanical material handling equipment. The hydraulic lifting and mechanical transport functions define its purpose. Chapter 84 covers fork-lift trucks and materials handling equipment.
Laptop Computer
A portable computer with integrated display, keyboard, touchpad, CPU, RAM, storage, and battery. Performs electronic data processing and runs various software applications.
Portable automatic data processing machines, weighing not more than 10 kg
Why Chapter 85: Primary function is electronic automatic data processing through microprocessors and digital circuits. Every core function (computing, display, storage, communication) is electronic. Mechanical components (keyboard, hinges, cooling fan) are purely auxiliary. Chapter 85 specifically covers automatic data processing machines.
Electric Conveyor Belt System
An industrial conveyor belt system with electric motor-driven rollers, belt mechanism, and support structure for continuous transport of materials in manufacturing facilities.
Belt type continuous-action elevators and conveyors
Why Chapter 84: The essential function is mechanical transport of materials through belt movement. Electric motors provide rotational power, but the conveyor’s purpose is mechanical material handling. The belt, rollers, and frame comprise the essential character. Chapter 84 specifically covers continuous-action conveyors for goods.
Electric Vehicle Charger (Level 2)
A Level 2 electric vehicle charging station with AC-to-DC converter, power management circuits, safety monitoring, and communication interface for charging EV batteries.
Static converters, power supplies
Why Chapter 85: The primary function is electrical energy conversion and power supply. The charger converts AC electricity to DC, manages power delivery electronically, and monitors charging status through electronic circuits. No mechanical action is involved—purely electrical conversion and control. Chapter 85 covers static converters and power supply units.
3D Printer (FDM Technology)
A fused deposition modeling (FDM) 3D printer with heated nozzle, mechanical X-Y-Z positioning system, extruder motor, and computerized control for layer-by-layer material deposition.
Other machinery for working rubber or plastics
Why Chapter 84: Despite computer control, the essential function is mechanical deposition and shaping of plastic material through heat and precision positioning. The printer performs mechanical work on physical materials (plastic filament). The process involves mechanical extrusion, heat treatment, and physical layer building. Additive manufacturing machines are classified as machines for working materials.
Smart Thermostat
A Wi-Fi connected programmable thermostat with touchscreen, temperature sensors, electronic control circuits, and mobile app connectivity for HVAC system control.
Electric control or distribution boards, ≤ 1,000 V
Why Chapter 85: The primary function is electronic control and regulation through electronic circuitry, sensors, and programmable logic. While it controls HVAC equipment (mechanical), the thermostat itself performs electronic sensing, data processing, and control signal generation. The product is an electronic control apparatus. Chapter 85 specifically covers electrical control panels and apparatus.
These case studies provide general guidance based on typical classifications. Actual HS code determination depends on specific product specifications, design, and functionality. Always verify classifications with:
- Official Harmonized Tariff Schedule of your importing country
- Customs binding rulings for similar products
- Licensed customs brokers or trade compliance professionals
- Manufacturer’s technical specifications and primary function documentation
Incorrect classification can result in significant penalties, duty adjustments, and shipment delays.
Quick Reference Guide: 5 Golden Rules
Don’t be distracted by auxiliary features. Ask: “What is this product’s main purpose?” A computer with cooling fans is primarily an electronic device, not a ventilation machine. A pump with electronic controls is primarily a mechanical device, not an electronic controller.
Many mechanical machines use electric motors for power. This doesn’t make them electrical apparatus. If electricity merely powers mechanical action (pumps, drills, conveyors), classify by the mechanical function in Chapter 84.
If the product could theoretically function mechanically without electronics (even if less efficiently), it’s likely Chapter 84. If electronics are absolutely essential to its primary function, consider Chapter 85.
Chapter 84 and 85 both contain detailed notes specifying what’s included and excluded. Note 2 to Chapter 85, for example, lists numerous mechanical devices that might seem “electrical” but belong in Chapter 84 (fans, sewing machines, vacuum cleaners).
Review customs rulings database for similar products. Customs authorities worldwide have issued thousands of binding rulings on specific products. These provide invaluable precedent for classification decisions.
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