WEBVTT

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Okay. Good afternoon, everyone.
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For those who don't already know me, my name is Matthew Sullivan and I am the national import
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specialist for automobiles, drones and tires. So between the continuing 301s and the possible 232
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investigation against European vehicles, motor vehicles have taken a very prominent place in the
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news and up on Capitol Hill. There are many vehicles that are included in Chapter 87 and there's
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no way that we're going to be able to cover them all today.
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But we are going to discuss the major vehicles of 8701 through 8710. Briefly touch on the 301
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investigation and some of their exemptions. And delve into the new technologies of hybrids,
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plug-in hybrids, and electric vehicles.
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Please note, I will be -- time allowing -- answering questions at the end of the
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presentation.
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But if you do have I any questions during the presentation, please put them in the chat box
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and I will respond to them at the end.
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Okay. So here we just have our familiar Mission Statement.
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Because many complicated factors can be involved in customs issues, an importer may wish to
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obtain a binding ruling under regulations of U.S. Customs & Border Protection, 19 CFR Part 177 or
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may wish to obtain advice from an expert who specializes in customs matters, for example a customs
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broker, attorney or consultant. And at the bottom we have the web address for submitting an
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electronic ruling request through the national commodities specialist division .
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Just a reminder that while this office does strive to provide correct and updated information,
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this information is advisory only. If there are any questions regarding specific commodities, it
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is up to you to request a binding ruling.
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So let's start at the beginning, work through the middle and when we get to the end, stop.
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First things first, Chapter 87 does not cover railway or tram way rolling stock designed solely
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for running on rails . This means no trains.
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Yes, trains are motorized. And yes, they provide transportation for both people and goods.
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But trains and the cars that are pulled along are provided for solely in Chapter 86 of the
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tariff.
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So what does Chapter 87 actually provide for?
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Tractors is 87.01. Motor vehicles for the transportation of person, which is 87.02 or 87.03.
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Motor vehicles for the transportation of goods, which is 87.04. Special purpose vehicles, which
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is 87.05. Work trucks, self-propelled, not fitted with lifting or handling equipment, of the
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type used in factories, warehouses, dock areas, or airports for short distance transport of goods
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and tractors of the type used on railway stations and platforms. 87.09.
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Armored fighting vehicles, motorized, Heading 87.10. Motorcycles and side cars, cycles and
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carriages for disabled people, whether or not motorized, Heading 87.11 through 87.13. Baby
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carriages of 87.15. Trailers and semi trailers and other vehicles not manually propelled, for
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example vehicles for towing by other vehicles being pushed or pulled by hand or being drawn by
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animals is 87.16 but since I'm only going to be talking about the motorized vehicles of Chapter
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87, let's just get rid of that extemporaneous material.
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An important note that incomplete or unfinished vehicles are classified as if they were
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complete or finished provided that the vehicle possesses the essential character of the complete
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vehicle. For example, a motor vehicle not fitted with the tires or the wheels which for tariff
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purposes are not interchangeable terms.
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We are told that a vehicle not equipped with its engine is considered complete, we see this as
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a difficult endeavor when many vehicles are actually classified by the engine size and fuel type.
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Cases like this binding rulings or calling or speaking directly to the importer can be very
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helpful.
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Here are some important terms that you should have at your disposal. Torque the turning or
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twisted effort usually mvd in foot pounds or newton meters.
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Horsepower, which is a -- measured -- which is a unit of force adequate 550 pounds per square
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inch. In vehicles what horsepower actually measures is the maximum rate of acceleration and the
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top pede of a car .
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Braking horsepower. This is a measurement of the horsepower of an engine without considering
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the loss of power that is caused by some parts of the engine like the generator, the gear box, the
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water pump and other auxiliary parts.
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There are no other key differences between brake horsepower and horsepower, other than the
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fact that when brake horsepower is measured, the engine torque is determined by applying a brake to
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the flywheel as opposed to using a torque converter like in the case of measuring horsepower.
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The chicken tax. The chicken tax is a 25% tariff on like trucks imported into the United
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States. Imposed in retaliation for European tariffs on American chicken imports, it was imposed
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in 1963 in an Executive Order issued by President Lyndon Johnson.
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And it is still in effect today.
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A cubic centimeter is a commonly used unit of volume that corresponds to the volume of a cube
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that measures 1 centimeter by 1 centimeter by 1 centimeter.
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1 cubic centimeter corresponds to the volume of 1 milliliter.
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A spark ignition engine is an internal combustion engine, generally a gas engine, where the
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combustion process called the air fuel mixture is initiated by a spark from a spark plug.
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In a diesel engine, ignition is produced by compressing the air and fuel in the cylinder which
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provides the necessary high temperature for combustion.
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A kilowatt is a measurement of 1,000 watts of electrical power. Tractors of 87.01 are
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classified by kilowatt output of the engine. In many cases, the importer will provide you with
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the engine's horsepower.
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To find the kilowatt divide the horsepower by 5.341 so a 450 horsepower engine produces 111.8
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kilowatts.
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So what does the tariff mean when it says tractor. Simply put a tractor is a wheeled or
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track-laying vehicle constructed essentially for hauling or pushing another vehicle, appliance or
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load.
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They may contain subsidiary provisions for transporting material in connection with their main
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use. These subsidiary provisions can be in the form of tools, feed fertilizeer spreaders or other
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goods or provisions for fitting with working tools . In layman's terms a tractor pulls or pushes
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something.
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Fork tractors are intended to position or shuttle trailers within a defined area. They are
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not suitable for long haul road use for which road tractors are designed they are tishable from
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road tractors they are usually equipped with a diesel engine the maximum speed not exceeding 30
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miles per hour and a small single seat enclosed cab for a single driver only. Terminal tractor.
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A road tractor refers to a motor vehicle which is designed to haul semi trailers over long
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distance.
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The road tractor and semi trailer form a combination known by various names.
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An articulated Laurie, a tractor-trailer, et cetera . Please remember that a tractor and
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trailer are classified separately, even if they are imported together either attached or in a
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common shipment.
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These vehicles usually contain disease Ellen jins and may be driven -- diesel engines and may
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be driven on road networks for example streets in general use, Avenues, Board of Directors and
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motor ways with fully loaded trailers. .
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8701 also covers tractors of other various types. For example tractors for agricultural or
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forestry work, road tractors, heavy duty tractors for constructional engineer work, wench
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tractors, et cetera. Whether their mode of propulsion is internal combustion, electric or diesel,
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it also includes tractors that can be used both on rails and on road but not those which are
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designed exclusively for use on rails, which as I mentioned earlier, are classified in Chapter
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86.
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The chassis of a tractor may be mounted on wheels or tracks or on a combination of wheels and
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tracks. In the last case, only the front steering axle is fitted with wheels.
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This heading also covers single axle tractors. Which are small agricultural tractors equipped
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with a single driving axle carried on one or two wheels.
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Like normal tractors they are designed for use with interchangeable implements which they may
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operate by means of a general purpose power takeoff.
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They are usually not fitted with a seat and steering is affected by meals of who handles those
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they may have rear carriages with a seat for the driver.
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8702 covers all vehicles designed to transport at least 10 people including the driver. This
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heading includes motor buses, coaches, trolley buses and gyro buses . They can all be powered by
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any type of motor.
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These are hopefully you are familiar with, motor buses, and Wisconsin you may never have seen
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before. Motor buses, an old fashioned term for a bus .
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A motorcoach comes in many different sizes and configurations. Simply put they are buses
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designed for a more comfortable ride and are usually typical for longer journeys. Many touring
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coaches have sleeping areas as well as kitchens and path rooms.
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Trolley bus is a bus powered by electricity obtained from an overhead cable by means of a
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trolley wheel. A major disadvantage is the inability to be moved or rerouted without additional
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cables and poles being installed along the new route.
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Now, here is an interesting vehicle, the gyro bus, the name comes from the Greek work for
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flywheel, gyros. Instead of carrying a battery or connecting to overhead power line a gyrobus
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carries a large flywheel spun up to 3,000 RPM by a squirrel cage motor. Power for charging the
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flywheel was sourced by means of three booms mounted on the vehicle's roof which contacted
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charging points located at the passenger stops on route or at terminals. To obtain tractor power
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capacitors would excite the flywheel's charging motor so it became a generator in this way
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transforming the energy stored in the flywheel back to electricity. This breaking was electric --
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was electric.
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-- vehicle braking was electric.
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And some of the energy was recycled back into the flywheel, thereby extending its range.
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Fully charged a gyrobus could typically travel at least as far as four miles on level routes at
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speeds up to 31 to 37 miles per hour, depending on the vehicle's passenger load charging a
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flywheel took between 30 seconds and 3 minutes while gyrobuses haven't been used in decades
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development in this area still continues.
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Let's look at a couple more definitions. Motor vehicles designed for the transportation of
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persons. 87.03.
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Motor vehicle, a road voybing powered by an engine. 8703 provides for motor cars and other
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motor vehicles principally designed for the transportation of persons.
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Motor car is a road vehicle powered by a motor designed to carry a driver and small number of
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passengers and usually have two front and two rear wheels. Passenger, a human being, maybe a
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dog.
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While all vehicles of 8703 are considered equal, there was a time when the interior volume
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ultimately determined the classification.
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It is still important to be able to identify the types of motor vehicles classified in 8703.
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First, we have the sedan.
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Which has a closed body and a closed trunk separated from the part in which the driver and
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passengers sit.
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Pronounced coupe, this is a car with a fixed roof, two doors and a sloping rear.
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A convertible comes with a folding or detachable roof.
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Sports utility vehicle or SUV is a car classification combines elements of road going
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passenger cars with features from offroad vehicles such as raised ground clearance and four-wheel
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drive there's no common definition of an SUV and use varies between countries some countries say
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an SUV must be built on a broader built chassis however some consider any vehicle with an offroad
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design feature to be a SUV a crossover SUV is a SUV built with a unibody like passenger cars
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however in many countries these are just referred to as SUVs. In some countries such as the
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United States SUVs have been classified as like trucks resulting in lenient regulations to
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passenger cars. This dates back to low volume moles from the late 1930s and four wheel drive
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station wagons and carryalls that began to be introduced in 1949.
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The 1984 Jeep Cherokee XJ is considered to be the first SUV in the modern style. Most SUVs
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produced today use unibody construction.
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However, in the past, many SUVs used body on frame construction.
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During the late 1990s and early 2000s, the popularity of SUVs grew greatly.
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Often at the expense of the popularity of large sedans and station wagons. More recently
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smaller SUVs, mid size and crossovers have become increasingly popular.
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SUVs are current the world's largest automobile segment and account for 36.8% of the world's
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passenger car market as reported in 2017.
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So let's take a quick look at the ENs. When in doubt, check the ENs, the ENs provide guidance
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on what is classified in each subheading. In this case it points out some of the features that
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while not definitive can provide a good basis for your classification.
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In the case of passenger vehicles, look for permanent seating with safety belts, passenger
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amenities such as speakers, heating/AC vents, entertainment systems, carpeting, an open area where
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passengers are seated together rather than separated by a barrier.
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Let's look at a few recent New York rulings that classified passenger vehicles.
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In the first case, we had a two-door electric vehicle used on private property or in bike
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lanes.
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The vehicle measured 87 inches long, 47 inches high, by 59 inches wide with 6 inches of ground
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clearance.
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The vehicle weighed approximately 816 pounds, and had a top speed of less than 20 miles an
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hour.
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The vehicle was classified in 8703.80.0000.
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Next, we have the Hyundai Nexo fuel cell model. The next owe was a five door -- Nexo was a
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five door sports utility vehicle powered by a fuel cell system with seating for five passengers .
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The Nexo was powered by a 161 horsepower electric motor. The Nex had a maximum driving range of
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approximately 370 miles.
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This vehicle was also classified in 8703.80.0000.
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Next we have the Ken Cona. The -- the Kona, the Kona is a five door SUV in two configurations
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first is a 2.0 liter 4 cylinder the second a 1.6 liter turbo 4 cylinder gas, spark ignition,
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internal combustion engine. Each model was equipped with seating for five people.
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Both models were classified in 8703.23.0140.
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Finally, we have the Solo electric car .
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The Solo was a 3 wheel single occupant vehicle powered solely by an electric motor.
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The vehicle provided a 100 mile range, with a top speed of 80 miles per hour.
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This vehicle was again classified in 8703.80.0000.
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So again, let's look at some more important terms.
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Motor vehicles designed for the transport of goods. 87.04. Again, motor vehicle. A road
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vehicle powered by an engine.
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And goods, items that are tangible, such as pens, salt, apples, computers, et cetera.
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A van is a medium-sized motor vehicle with a boxy shape and high roof, used for transporting
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goods or passengers. In this case, we are looking at cargo vans. Not passenger vans, that may be
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classified in either 8702 or 8703.
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In 2009 Ford began importing their transit connect vans into the United States in the port of
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Baltimore they were driven across the street to the facilities where rear side windows and seats
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were removed with metal plates and floorboards Ford claimed they were getting passenger vans and
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converted them to cargo vans once in the United States to avoid the 25% chicken tax they even went
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so far as to boast in a news article that what they were doing was legal. But was it. Not
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exactly. A tariff engineer or working an article to get a more favorable tariff late is legal is a
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legal way to navigate the HTS what Ford was doing was far from legal what they were doing is
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disguiseing the vehicles as a passenger van over to remove the mask after it had left the port an
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investigation initiated by this office, the Department of Transportation, and the port of
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Baltimore uncovered that, one, Ford was importing the passenger vans even if the customer had
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ordered a cargo van.
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That Ford was able to perform the entire conversion process in less than 15 minutes.
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And that CBP could pick out the vans set up for conversion because they were configured
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differently internally.
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While all of the vans were equipped with rear seats, the vans converted had cheaper seats in
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the rear that did not match the front seating. They were missing air ducts and speakers and
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other passenger amenities that were standard on the actual passenger van.
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The case was tried in front of the court of international trade in New York City.
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In that case, CBP lost. But the decision was to -- the decision so extremely went against
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over 100 years of precedence that CBP immediately filed an appeals in the Federal Appellate Court
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which reversed the decision in June of 2019. Ford appealed this decision to the Supreme Court.
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The misclassification resulted in the collection of over $300 million.
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In June of 2020, the Supreme Court of the United States declined to entertain Ford's request
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for a hearing the decision of the Appellate Court was upheld the case is now in the penalty phase
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where CBP could potentially collect additional duties and fines.
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Pickup is a small truck with an enclosed cab and an open back.
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A dumper is an automotive truck for the transportation of bulk material that has a body which
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tilts to dump its contents.
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Now, a multi-purpose vehicle is a large car typically seating six or more that is capable of
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being driven offroad . This may include some SUVs where the vehicle is equally capable of
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transporting goods or people.
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There are many types of tons. The short ton. The long ton. And finally the metric ton.
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All are different but which is used when classifying vehicles of 8704? In the United States a
00:26:37.334 --> 00:26:40.759
ton is a unit of weight adequate 2,000 pounds.
00:26:40.759 --> 00:26:49.736
It is called a ton or sorry; a short ton to differentiate it from the larger British ton,
00:26:49.736 --> 00:26:55.131
which weighs 2240 pounds. Which is referred to as the long ton.
00:26:55.131 --> 00:27:04.901
There is also an in-between, which is a third type called the metric ton, which equals to
00:27:04.901 --> 00:27:10.049
1,000 kilograms or approximately 2204 pounds.
00:27:10.049 --> 00:27:16.611
The metric ton is officially called tonne, t-o-n-n-e.
00:27:16.611 --> 00:27:24.675
It is this weight that we use for classifying vehicles of 8704. For example an offroad dumper
00:27:24.675 --> 00:27:42.192
with a capacity of 40.8 metric tons or less would mean a capacity of less than 89,923 pounds.
00:27:42.192 --> 00:27:49.437
The actual weight of a car is known as the gross vehicle mass or weight. The GVW.
00:27:49.437 --> 00:27:55.115
It refers to the current weight of a vehicle with all of its parts and everything inside of
00:27:55.115 --> 00:27:58.029
it, including cargo and passengers.
00:27:58.029 --> 00:28:06.603
On the other hand, the gross vehicle weight rating or GVWR, indicates the highest load that an
00:28:06.603 --> 00:28:08.155
automobile can carry.
00:28:08.155 --> 00:28:14.193
This number is assigned by the manufacturer and does not change under any circumstances.
00:28:14.193 --> 00:28:21.097
It includes the weight of all the components of the car, the driver, the passenger, the cargo,
00:28:21.097 --> 00:28:23.168
fuel, and other things.
00:28:23.168 --> 00:28:29.584
Although the tariff uses the term gross vehicle weight, the explanatory note defines it as
00:28:29.584 --> 00:28:36.613
being the road weight specified by the manufacturer as being the maximum design weight capable of
00:28:36.613 --> 00:28:37.491
vehicle.
00:28:37.491 --> 00:28:44.903
This weight is the combined weight of the vehicle, the maximum specified load, the driver and
00:28:44.903 --> 00:28:51.887
a tank full of fuel which according to the industry is actually the gross vehicle weight rating.
00:28:51.887 --> 00:28:58.376
It is important to understand the difference between the GVW and the GVWR.
00:28:58.376 --> 00:29:04.681
The second one remains constant, while the first one can change.
00:29:04.681 --> 00:29:11.870
For example, your car will have one GVW when there are two passengers. But the number will
00:29:11.870 --> 00:29:13.740
change if one of them exits.
00:29:13.740 --> 00:29:19.765
The gross vehicle weight should never exceed the gross vehicle weight rating to ensure
00:29:19.765 --> 00:29:22.718
safety.
00:29:22.718 --> 00:29:27.440
The curb weight is the weight of the car without any additional items.
00:29:27.440 --> 00:29:33.103
It includes the standard weight of the vehicle and counts the weight of 90% fuel in a fuel
00:29:33.103 --> 00:29:34.645
tank.
00:29:34.645 --> 00:29:43.491
A cab chassis, also known as a chassis cab, or half truck, is a type of vehicle construction
00:29:43.491 --> 00:29:47.695
often found in medium duty truck commercial vehicles.
00:29:47.695 --> 00:29:53.862
Instead of supplying the customer with a preassembled flatbed cargo container or other
00:29:53.862 --> 00:29:59.735
equipment, the customer is given the vehicle with just the chassis rails and a cab. This allows
00:29:59.735 --> 00:30:06.852
the customer to add any desired aftermarket equipment such as fire apparatus, ambulance,
00:30:06.852 --> 00:30:11.581
recreational vehicle conversion package, which can be customized for the specific need of the
00:30:11.581 --> 00:30:12.898
customer.
00:30:12.898 --> 00:30:24.063
Please note that these features are important and can sometimes change classification.
00:30:24.063 --> 00:30:33.398
When the explanatory note says the presence of bench Type seats without safety equipment it
00:30:33.398 --> 00:30:39.674
means seat belts. This doesn't mean the presence of seat belts removes it from 8704 but you
00:30:39.674 --> 00:30:44.830
should look at the vehicle and try not to focus on one specific feature or lack of that feature
00:30:44.830 --> 00:30:50.006
when you're classifying a vehicle of 8704.
00:30:50.006 --> 00:30:58.029
While vehicles of 8703 were once classified by interior volume, vehicles of 8704 are still
00:30:58.029 --> 00:31:03.825
classified by the weight that the vehicle can transport. Weight in 8704 is measured in either
00:31:03.825 --> 00:31:09.239
metric tons when we classify a dumper or the gross vehicle weight when we're classifying any other
00:31:09.239 --> 00:31:11.497
type of cargo vehicle.
00:31:11.497 --> 00:31:25.146
Here we see a couple of New York rulings that determined classification was in 8704.
00:31:25.146 --> 00:31:52.170
Sometimes we need to classify vehicles that are conceptual in nature and will never actually
00:31:52.170 --> 00:31:54.787
be used on public roads.
00:31:54.787 --> 00:32:16.820
Please note that in N287720, even though the vehicle was not designed to travel over 25 miles
00:32:16.820 --> 00:32:23.419
an hour, it was still designed to transport goods in an open air cargo bed.
00:32:23.419 --> 00:32:39.162
The cooler scooter was a four week vehicle that was offered with two engine options a 49 CC 2
00:32:39.162 --> 00:32:46.695
stroke or 33 CC 4 stroke engine both engines operated by spark ignition internal combustion their
00:32:46.695 --> 00:32:53.936
horsepower was rated at approximately 1.5 horsepower and they each had a fuel capacity of .16
00:32:53.936 --> 00:32:59.513
gallons a plastic cooler was specially designed for and permanently attached to the vehicle.
00:32:59.513 --> 00:33:05.524
The cooler scooter was used to transport a person and picnic supplies a short distance to
00:33:05.524 --> 00:33:07.429
offroad locations.
00:33:07.429 --> 00:33:14.276
In April 2008, cooler scooter requested a reconsideration of the New York ruling . By
00:33:14.276 --> 00:33:22.798
application of GRI 1 headquarters found that the cooler scooter was classifiable under 8704. And
00:33:22.798 --> 00:33:34.719
confirmed classification in 8704.31.00.
00:33:34.719 --> 00:33:39.004
There have been many questions when it comes to Land Rovers specifically. And whether they are
00:33:39.004 --> 00:33:53.178
classified in 8703 or 8704 land rovers like the Willie jeep were used by arm forces of ewe United
00:33:53.178 --> 00:34:01.279
Kingdom for versatility they can transport cargo, people, people and cargo, as an ambulance or
00:34:01.279 --> 00:34:07.587
armored transport et cetera in the above examples this vehicle is equipped with four doors for
00:34:07.587 --> 00:34:14.162
passengers but also has an open cargo area in the back. Note the tire. This does not limit the
00:34:14.162 --> 00:34:21.858
cargo ability. The classification of goods in the HTS U.S. is governed by the general rules of
00:34:21.858 --> 00:34:30.912
interpretation GRI -- GRI 3 states that when application of Rule 2B or for any other reason they
00:34:30.912 --> 00:34:39.278
are prime face I can't classification is as following when goods can't be classified to 3A or 3B
00:34:39.278 --> 00:34:46.356
they shall be classified under the heading which occurs last in numerical order among those which
00:34:46.356 --> 00:34:48.035
equal merit consideration .
00:34:48.035 --> 00:34:55.932
Some land rovers are equipped with bench seating in the rear without safety belts. These
00:34:55.932 --> 00:35:02.959
vehicles are 8704. If the vehicle bolts a seat in the rear but there's no other passenger amenity
00:35:02.959 --> 00:35:05.901
in the rear, it's still probably 8704.
00:35:05.901 --> 00:35:12.960
When in doubt, you can always send in for a binding ruling to request guidance.
00:35:12.960 --> 00:35:28.184
8705 provides for vehicles, motor vehicles, other than those used for the transport of people
00:35:28.184 --> 00:35:34.200
or goods. These vehicles may carry people or what appears to be cargo but they really serve a
00:35:34.200 --> 00:35:40.366
function. For example a concrete mixer is designed to constantly mix concrete rather than just
00:35:40.366 --> 00:35:45.951
being a vehicle for transporting the concrete.
00:35:45.951 --> 00:35:55.844
Let's look at some of the exemplars described in the heading. Wreckers are tow trucks.
00:35:55.844 --> 00:36:00.331
Mobile cranes are machines used for moving heavy objects by suspending them from a projecting arm
00:36:00.331 --> 00:36:06.502
or beam.
00:36:06.502 --> 00:36:11.278
Firefighting vehicles are vehicles that carry firefighters and equipment for fighting large
00:36:11.278 --> 00:36:12.707
fires.
00:36:12.707 --> 00:36:21.794
Please note that they actually can be equipped with trades or tracks.
00:36:21.794 --> 00:36:33.528
Again, concrete mixers are vehicles with a barrel shaped rotating body used to mix concrete.
00:36:33.528 --> 00:36:36.892
Road sweepers are machines that clean streets.
00:36:36.892 --> 00:36:42.825
So let's look at the ENs.
00:36:42.825 --> 00:36:50.323
8705 covers a range of motor vehicles, specifically designed or adapted equipped with various
00:36:50.323 --> 00:36:57.982
devices that enable them to perform certain non-transport functions. For example, the primary
00:36:57.982 --> 00:37:03.441
purpose of the vehicle of this heading is not for the transportation of people or goods.
00:37:03.441 --> 00:37:23.253
This heading includes the motor breakdown Lori trucks, tow trucks, motor pump vehicles with a
00:37:23.253 --> 00:37:32.709
pump usually driven by the engine's vehicles, fire truck. Snowplows or snowblowers with built-in
00:37:32.709 --> 00:37:39.432
equipment and mobile drilling Derricks that are fitted with a derrick assembly wivrjs and other
00:37:39.432 --> 00:37:46.806
appliances for -- winchs and other fittings for drilling.
00:37:46.806 --> 00:37:55.296
8709 covers a group of self-propelled vehicles of the type uses in factories, warehouses,
00:37:55.296 --> 00:38:01.793
docks or airports for the short distance trans for the of various -- transport for containers or
00:38:01.793 --> 00:38:05.418
railway station platforms to haul small strairls.
00:38:05.418 --> 00:38:10.934
Such vehicles are many types and sizes that can be driven either by electric motors with
00:38:10.934 --> 00:38:15.707
currents supplied by accumulateers or by internal combustion piston engines or other types of
00:38:15.707 --> 00:38:17.197
engines .
00:38:17.197 --> 00:38:22.747
The main features common to these vehicles which will generally distinguish them from vehicles
00:38:22.747 --> 00:38:30.581
of 8701, 8703 or 8704 may be summarized in the following.
00:38:30.581 --> 00:38:37.192
Their construction and as a rule their special design features make them unsuitable for the
00:38:37.192 --> 00:38:45.282
transport of people or the transport of goods by road or other public ways.
00:38:45.282 --> 00:38:53.311
Their top speed is generally not more than 30 to 35 kilometers an hour which converts to
00:38:53.311 --> 00:38:57.862
between 18 and 21 miles per hour.
00:38:57.862 --> 00:39:08.128
And finally, their turning radius is approximately equal to the length of the vehicle itself.
00:39:08.128 --> 00:39:15.345
Now, the term turning radius is a technical term that has become popular automotive jargon.
00:39:15.345 --> 00:39:22.283
In the jargon sense, it is commonly used to mean the full diameter of the smallest circle.
00:39:22.283 --> 00:39:27.990
But in technical usage, the turning radius is still used to denote the radius.
00:39:27.990 --> 00:39:39.278
As an example, motor trend refers to the curb to curb turning radius of a 2008 Cadillac CTS as
00:39:39.278 --> 00:39:44.650
35.5 feet or 10.82 meters.
00:39:44.650 --> 00:39:49.143
It is often used as a generalized term rather than as a numerical figure.
00:39:49.143 --> 00:39:55.172
For example, a vehicle with a very small turning radius may be described as just simply having
00:39:55.172 --> 00:39:57.540
a tight turning radius.
00:39:57.540 --> 00:40:01.532
Two different measurements can be quoted for a vehicle.
00:40:01.532 --> 00:40:07.974
A curb to curb turning radius will show a straight line distance from one side of the street to
00:40:07.974 --> 00:40:09.995
the other through the center.
00:40:09.995 --> 00:40:18.010
The name curb to curb indicates that a street would have to be this X wide before the vehicle
00:40:18.010 --> 00:40:22.532
can make a U turn and not hit the street curb with a wheel.
00:40:22.532 --> 00:40:29.826
If you look at the curb and build it to chest height then try to make a U turn in the street,
00:40:29.826 --> 00:40:34.119
parts of the car would hit the frame, the wall.
00:40:34.119 --> 00:40:41.149
The name wall or wall to wall turning circle denotes how far the two walls would have to be to
00:40:41.149 --> 00:40:47.139
allow a full U turn without scraping.
00:40:47.139 --> 00:40:53.126
A notable exception in this description is vehicles that are capable of spinning around their
00:40:53.126 --> 00:40:59.763
central axle such as certain lawn mowers, wheelchairs as they do not follow a circular path as
00:40:59.763 --> 00:41:00.350
they turn.
00:41:00.350 --> 00:41:08.079
In this case the vehicle is referred to as having a zero radius -- zero turning radius.
00:41:08.079 --> 00:41:18.036
Some camera dollies used in the film industry also has a round mode which allows them to spin
00:41:18.036 --> 00:41:25.616
around the Z axis by allowing rotation in the front and rear wheel sets effectively giving them a
00:41:25.616 --> 00:41:32.744
zero turning radius for vehicles of 8709 to have a turning radius adequate its length means the
00:41:32.744 --> 00:41:40.449
truck turns on its axis, a zero turning radius. This is important because of the tight confines
00:41:40.449 --> 00:41:54.356
that these types of vehicles will often work in, such as warehouses.
00:41:54.356 --> 00:41:59.991
So getting back to vehicles of 8709. Vehicles of this heading do not usually have a closed
00:41:59.991 --> 00:42:04.280
driving cab. The accommodations of the driver often being no more than a platform on which he
00:42:04.280 --> 00:42:08.715
stands to steer the vehicle.
00:42:08.715 --> 00:42:17.794
Certain types movie with a protective frame metal clasps et cetera over the driver's seat this
00:42:17.794 --> 00:42:22.097
can also be pedestrian controlled. Work trucks are self-propelled trucks for the transport of
00:42:22.097 --> 00:42:30.114
goods which are fitted with, for example, a platform or container on which the goods are loaded.
00:42:30.114 --> 00:42:37.412
Small tank trucks of a kind generally used in railway stations, whether or not fitted with
00:42:37.412 --> 00:42:41.455
subsidiary pumps are also classified here.
00:42:41.455 --> 00:42:48.180
Tractors of the type used on railway station platforms are designed primarily to toe or push
00:42:48.180 --> 00:42:56.060
other vehicles, for example small trailers but they are not classified in 8701. Although they
00:42:56.060 --> 00:43:03.413
themselves don't carry the goods and generally lighter and less powerful than tractors of 8701
00:43:03.413 --> 00:43:16.646
these types of tractors are also used in wharfing and warehouses and are classifiable in 8709.
00:43:16.646 --> 00:43:24.326
While many people try to fit various ATVs, UTVs and other offroad vehicles as work trucks
00:43:24.326 --> 00:43:29.372
these are examples of the types of vehicles that are meant to be classified in 8709 as work
00:43:29.372 --> 00:43:40.807
trucks.
00:43:40.807 --> 00:43:46.085
Although they are not often imported in addition to vehicles you will see on the street 87
00:43:46.085 --> 00:43:51.111
provides for some vehicles that you may see only during parades, specifically Memorial Day.
00:43:51.111 --> 00:43:59.027
So what are tanks and armored vehicles?
00:43:59.027 --> 00:44:04.572
Simply put, they are armored military vehicles. There are other types of armored vehicles
00:44:04.572 --> 00:44:12.448
such as ones to transport dignitaries and currency but these are not class finally in 8710 --
00:44:12.448 --> 00:44:17.721
classifiable in 8710 they are classified as goods transporting the people or transporting the
00:44:17.721 --> 00:44:29.120
goods. So in order to go in 8710, it has to be a military vehicle.
00:44:29.120 --> 00:44:39.124
8710 also covers tanks equipped with a crane with the recovery of fighting vehicles.
00:44:39.124 --> 00:44:44.840
Armored supply vehicles generally of the track-laying type, whether they are designed to be
00:44:44.840 --> 00:44:52.961
armed or not, are used for the transport of petroleum, ammunition, et cetera, into fighting
00:44:52.961 --> 00:45:00.759
areas.
00:45:00.759 --> 00:45:07.667
8710 also provides for small remote controlled tanks which cover ammunition to advance
00:45:07.667 --> 00:45:16.489
fighting vehicles or artillery units.
00:45:16.489 --> 00:45:21.045
Armored personnel carriers.
00:45:21.045 --> 00:45:26.043
And finally, armored vehicles permanently fitted with special demolition equipment.
00:45:26.043 --> 00:45:40.745
In many cases, these are just heavily modified bulldozers or other types of vehicles.
00:45:40.745 --> 00:45:44.036
Let's say hello to hybrids and electrics.
00:45:44.036 --> 00:45:54.185
Pure electric vehicles are vehicles powered only by battery and are classifiable in
00:45:54.185 --> 00:45:57.319
8703.80.00.
00:45:57.319 --> 00:46:04.792
Plug-in hybrids have an internal combustion engine but also a battery range in excess of 10
00:46:04.792 --> 00:46:05.195
miles.
00:46:05.195 --> 00:46:12.738
After the battery range is reached, the vehicle reverts to the benefits of full hybrid
00:46:12.738 --> 00:46:17.706
capabilities. Classifiable in 8703.60.
00:46:17.706 --> 00:46:26.132
Extended range electric vehicles are like pure leaking vehicles but with a shorter brat --
00:46:26.132 --> 00:46:33.392
pure electric vehicles with a shorter battery. They have a combustion generator which provides
00:46:33.392 --> 00:46:39.180
many additional miles of mobility . With an extended range electric vehicle, the propulsion is
00:46:39.180 --> 00:46:45.215
always electric unlike a plug-in hybrid where the propulsion can be either electric or full
00:46:45.215 --> 00:46:46.208
hybrid.
00:46:46.208 --> 00:46:52.099
The standard hybrid electric vehicle are vehicles that are not capable of charging the battery
00:46:52.099 --> 00:46:58.587
externally.
00:46:58.587 --> 00:47:05.520
Although the explanatory notes still generate -- sorry; electric vehicles still generate tire
00:47:05.520 --> 00:47:11.644
noise, the level is much lower than an internal combustion engine car, particularly at low
00:47:11.644 --> 00:47:13.609
speeds.
00:47:13.609 --> 00:47:19.338
Sight and hearing impaired people can be particularly vulnerable. So drivers need to be aware
00:47:19.338 --> 00:47:22.999
of this and take extra care.
00:47:22.999 --> 00:47:29.576
One common myth regarding electric vehicles is that they are slow. This could not be farther
00:47:29.576 --> 00:47:36.221
from the truth. The electric motor in an EV produces 100% of its torque instantaneously. This is
00:47:36.221 --> 00:47:39.247
the same at all speeds.
00:47:39.247 --> 00:47:44.422
In other words, a flat torque curve.
00:47:44.422 --> 00:47:51.586
The top version of the Tesla Model S went in ludicrous mode is one of the quickest production
00:47:51.586 --> 00:48:02.110
cars in the world. It has a 0 to 60 time of 2.5 seconds. The Volkswagen GT plug-in hybrid
00:48:02.110 --> 00:48:07.285
electric vehicle when in pure electric mode will spin the front tires if the traction control is
00:48:07.285 --> 00:48:10.289
not engaged.
00:48:10.289 --> 00:48:12.648
Electric vehicles are not slow.
00:48:12.648 --> 00:48:19.631
Another myth is that the power grid will not be able to handle the extra load.
00:48:19.631 --> 00:48:25.624
Power grids across the United States, the United Kingdom and the EU can handle the expected
00:48:25.624 --> 00:48:32.781
growth of electric vehicles for the foreseeable future without any significant change.
00:48:32.781 --> 00:48:38.075
This is because most electric vehicles tend to be charged at night during offpeak hours and
00:48:38.075 --> 00:48:40.011
when demand is usually at its lowest.
00:48:40.011 --> 00:48:46.303
To balance the grid, it will be necessary to agree to methods of timing such as competitive
00:48:46.303 --> 00:48:57.121
pricing for charging EVs during certain hours.
00:48:57.121 --> 00:49:03.144
Electric vehicles, pure or hybrid, use high voltage batteries so that the energy can be
00:49:03.144 --> 00:49:11.255
delivered to a drive motor or returned to a battery pack in a very short time. The Honda insight
00:49:11.255 --> 00:49:18.296
system for example uses a 144 volt battery module to star regenerated energy.
00:49:18.296 --> 00:49:29.498
The Toyota Prius originally used 273.6 volt battery but this was changed in 2004 to a 201.6
00:49:29.498 --> 00:49:30.993
volt pack.
00:49:30.993 --> 00:49:38.753
Hybrid vehicles use at least one electric drive motor in addition to the internal combustion
00:49:38.753 --> 00:49:39.494
engine.
00:49:39.494 --> 00:49:44.124
There are several different ways in which this can be combined. And a number of different
00:49:44.124 --> 00:49:46.193
motors and engines.
00:49:46.193 --> 00:49:51.288
Note that for clarity, we will only -- we will be generally referring to the internal
00:49:51.288 --> 00:49:57.351
combustion engine as an engine and the electric drive motor as a motor.
00:49:57.351 --> 00:50:03.498
Take care, though, in other parts of the world, the internal combustion engine can be referred
00:50:03.498 --> 00:50:08.605
to as a motor.
00:50:08.605 --> 00:50:14.000
On all types of electric vehicles during braking, the motor becomes a generator and the energy
00:50:14.000 --> 00:50:19.916
that would normally be wasted as heat from the brakes is converted into electrical energy and
00:50:19.916 --> 00:50:23.629
stored in the battery regenerative braking system.
00:50:23.629 --> 00:50:30.519
Not all hybrids are the same.
00:50:30.519 --> 00:50:37.028
Some are more dependent on the hybrid system for propulsion as others, some are not classified
00:50:37.028 --> 00:50:37.788
as hybrids at all.
00:50:37.788 --> 00:50:43.369
Let us look at the level of hybridization.
00:50:43.369 --> 00:50:51.932
A stop-start system has the functions of a stop/start as well as some regenerative. The
00:50:51.932 --> 00:50:56.370
control of the normal vehicle alternator is adapted to achieve this. During normal driving the
00:50:56.370 --> 00:51:02.707
alternator operates with low output. During overrun, which is the continue of a vehicle traveling
00:51:02.707 --> 00:51:10.187
without throttle, the alternator output is increased in order to increase the increase in battery
00:51:10.187 --> 00:51:13.265
effect to increase power generation.
00:51:13.265 --> 00:51:22.301
Stopping the engine when idling saves fuel and reduces emissions.
00:51:22.301 --> 00:51:29.700
The mild hybrid provides some assistance during acceleration, particularly at low speed.
00:51:29.700 --> 00:51:33.819
Pure electric propulsion is not possible.
00:51:33.819 --> 00:51:41.261
The motor may be able to propel the vehicle but the internal combustion engine is always
00:51:41.261 --> 00:51:41.821
running.
00:51:41.821 --> 00:51:48.750
A strong hybrid takes all of the above functions further and over short distances, the
00:51:48.750 --> 00:51:55.027
internal combustion engine can be switched off to allow for pure electric operation.
00:51:55.027 --> 00:52:01.650
The plug-in hybrid is a strong hybrid but with a larger high vaelt battery that can be charged
00:52:01.650 --> 00:52:05.507
from a suitable electrical power supply.
00:52:05.507 --> 00:52:13.103
A hybrid power system for an automobile can have the -- be in a series, a parallel, or a power
00:52:13.103 --> 00:52:17.029
split configuration.
00:52:17.029 --> 00:52:21.614
With a series system the internal combustion engine drives a generator which in turn powers a
00:52:21.614 --> 00:52:24.274
motor. And the motor propels the vehicle.
00:52:24.274 --> 00:52:32.828
With a parallel system, the engine and the motor can both be used to propel the vehicle.
00:52:32.828 --> 00:52:35.864
Most hybrids in current use employ a parallel system.
00:52:35.864 --> 00:52:42.211
The power split has additional advantages. But it is also much more complex.
00:52:42.211 --> 00:52:52.369
So as you can see in a parallel system, both the engine and the electric motor are coupled to
00:52:52.369 --> 00:52:54.686
the wheel that propels the vehicle.
00:52:54.686 --> 00:53:01.710
In the series hybrid, the electric motor handles all the driving and the gasoline engine is
00:53:01.710 --> 00:53:05.405
only used to recharge the battery pack.
00:53:05.405 --> 00:53:13.184
In a power split or a series parallel hybrid, this allows for the power to the wheels to be
00:53:13.184 --> 00:53:15.857
either mechanical or electrical.
00:53:15.857 --> 00:53:31.899
The most common battery technology now in use is the Lithium ion. The complete battery pack
00:53:31.899 --> 00:53:38.086
consists of a number of cell modules. The actual battery consisting of approximately 2 to 300
00:53:38.086 --> 00:53:38.671
cells.
00:53:38.671 --> 00:53:46.633
A cooling system, insulation, a junction box, battery management and a suitable case or
00:53:46.633 --> 00:53:47.253
shell.
00:53:47.253 --> 00:53:53.244
These features combine so that the pack can withstand impacts and a wide range of temperatures.
00:53:53.244 --> 00:53:56.360

00:53:56.360 --> 00:54:00.406
The battery management control is a device that monitors and controls the battery and
00:54:00.406 --> 00:54:04.484
determines among other things the state of charge of the cells.
00:54:04.484 --> 00:54:11.517
It regulates the temperature and protects the cells from overcharging and deep discharge.
00:54:11.517 --> 00:54:16.539
Electronically activated switches are included that disconnect the battery system when idle
00:54:16.539 --> 00:54:22.894
and in critical situations such as an accident or fire.
00:54:22.894 --> 00:54:28.751
The motor is the component that converts the electric energy into the kinetic energy or
00:54:28.751 --> 00:54:32.965
movement. In other words, it's what moves the vehicle.
00:54:32.965 --> 00:54:46.079
Most types used on EVs, hybrid EVs, and plug-in EVs are a type of AC sin conious motor
00:54:46.079 --> 00:54:53.785
supplied with pulses of DC. They are rated in the region of 85 kilowatts on pure electric power
00:54:53.785 --> 00:54:53.816
.
00:54:53.816 --> 00:55:01.985
The inverter is an electronic device or circuit that changes the direct current DC from the
00:55:01.985 --> 00:55:05.294
battery into alternating current, AC to drive the motor.
00:55:05.294 --> 00:55:09.362
It does this in reverse for regenerative braking.
00:55:09.362 --> 00:55:13.920
It is often described as the power electronics or similar.
00:55:13.920 --> 00:55:22.030
Sometimes the same or separate inverter is used to is a supply the 12 volt system.
00:55:22.030 --> 00:55:30.266
The control unit, also called the power supply unit or motor control unit is the electronic
00:55:30.266 --> 00:55:35.413
device that controls the inverter. It responds to signals from the driver, for example braking,
00:55:35.413 --> 00:55:39.659
acceleration, et cetera, and causes the power electronics to be switched accordingly.
00:55:39.659 --> 00:55:45.531
The controller makes the motor drive the car. Or it becomes the generator and charges the
00:55:45.531 --> 00:55:46.176
battery.
00:55:46.176 --> 00:55:51.985
It can also be responsible for the air conditioning, the power assisted steering and the
00:55:51.985 --> 00:55:52.742
brakes.
00:55:52.742 --> 00:56:01.100
The charging unit is the device used on pure electric vehicles and plug-in hybrid vehicles.
00:56:01.100 --> 00:56:05.602
And is usually located somewhere near the external power source it's connected to.
00:56:05.602 --> 00:56:13.302
This converts and controls the main voltage, typically 120 volts AC in the United States to a
00:56:13.302 --> 00:56:19.987
typical level of charging for the battery cell which is typically 300 volts DC.
00:56:19.987 --> 00:56:29.302
The driver interface is used to keep the driver informed. A inch of methods is used. Most
00:56:29.302 --> 00:56:34.843
common now is a touchscreen interface where information can be delivered as well as allowing the
00:56:34.843 --> 00:56:45.816
driver to change settings such as the charge rate.
00:56:45.816 --> 00:56:53.423
The normal run -- thermal runaway is done by increased temperature in turn releasing energy
00:56:53.423 --> 00:57:01.194
with temperature. Thermal runaway occurs when the temperature changes a condition which causes a
00:57:01.194 --> 00:57:05.612
further increase in temperature often leading to a destructive result. It is a kind of
00:57:05.612 --> 00:57:09.410
uncontrolled positive feedback.
00:57:09.410 --> 00:57:14.849
An exothermic reaction increases the body's temperature and therefore the internal pressure of
00:57:14.849 --> 00:57:20.721
the Lithium ion battery gas evolution also increases the pressure of the cell. If the cell is
00:57:20.721 --> 00:57:29.215
equipped with a pressure release valve which is not found on port shelves the valve will open and
00:57:29.215 --> 00:57:36.493
release flammable organic compounds a pouch cell melt which usually you would see in a cell phone
00:57:36.493 --> 00:57:42.673
or a laptop computer, may burst if the internal pressure becomes too high. Sometimes you see this
00:57:42.673 --> 00:57:46.341
with bulging batteries.
00:57:46.341 --> 00:57:53.211
The emissions of organic carbonates can be seen as WhiteSmoke during further heating of the
00:57:53.211 --> 00:58:01.381
cell the color of the smoke turns gray indicating active material graphite is burning away the
00:58:01.381 --> 00:58:09.870
process can generate temperatures of 700 to 1,000 degrees Celsius or 1292 to 1832 degrees
00:58:09.870 --> 00:58:10.794
Fahrenheit.
00:58:10.794 --> 00:58:19.038
This high temperature may affect adjunct -- adjacent cells and cause a chain reaction.
00:58:19.038 --> 00:58:28.138
With the organic solvents, the conducting salts, Lithium PF6 is also emitted and reacts as
00:58:28.138 --> 00:58:36.709
following, when in a dry heated environment, the salt will decompose. But if it becomes in
00:58:36.709 --> 00:58:43.772
contact with water or air molecules, toxic hydrogen fluoride gas is created.
00:58:43.772 --> 00:58:50.957
When a thermal runaway occurs a large number of different kinds of chemicals are generated.
00:58:50.957 --> 00:59:00.025
Combustion reactions mainly create carbon dioxide, carbon monoxide knight oxide -- nitrogen oxide
00:59:00.025 --> 00:59:07.235
hydrogen fluoride low molecular weight organic acids,al collides and ketones although a Lithium ion
00:59:07.235 --> 00:59:14.079
battery fire should not normally be distinguished with pure water using plenty of water may be
00:59:14.079 --> 00:59:18.140
reasonable because it cools down the surrounding cells to avoid the runaway process.
00:59:18.140 --> 00:59:24.986
Additionally many of the emitted pearls and toxic gas and compounds will bind and will be
00:59:24.986 --> 00:59:28.980
diluted by water .
00:59:28.980 --> 00:59:40.779
What happens when you turn on an electric or hybrid vehicle? The off position the relays are
00:59:40.779 --> 00:59:42.541
operated in a defined sequence.
00:59:42.541 --> 00:59:48.416
In startup, when the vehicle is first switched on the precharged contacts close for a short
00:59:48.416 --> 00:59:54.809
time and then open again. This allows a test to be carried out as node current should be flowing.
00:59:54.809 --> 01:00:00.332
Next the main negative contacts are closed again. This allows circuit testing.
01:00:00.332 --> 01:00:07.919
The precharge contacts close again. And the capacitor charges from the high voltage battery
01:00:07.919 --> 01:00:14.387
through a resistor to limit the current. Finally the main positive contacts are closed, the
01:00:14.387 --> 01:00:18.798
capacitor fully charges and the system is now described as going in ready mode.
01:00:18.798 --> 01:00:24.604
The precharge feature is to protect the battery as well as allowing diagnostic functions.
01:00:24.604 --> 01:00:31.751
The ready position, the two main contacts remain closed. And the vehicle can be used as
01:00:31.751 --> 01:00:35.017
normal.
01:00:35.017 --> 01:00:41.550
In ready or similar position is normally displayed on the Control Panel. In a shutdown when
01:00:41.550 --> 01:00:50.351
the vehicle is switched off, the main positive contact is opened and the capacitor discharges once
01:00:50.351 --> 01:00:55.869
fully discharged the system is considered to be off. This discharge happens in two different
01:00:55.869 --> 01:00:57.609
ways. Active and passive.
01:00:57.609 --> 01:01:05.938
In active, the active discharge function is reduced -- reducing the high voltage to less than
01:01:05.938 --> 01:01:07.734
60 volts within 4 seconds.
01:01:07.734 --> 01:01:13.769
To do this, the transistors in the inverter are closed which effectively discharges the
01:01:13.769 --> 01:01:19.188
capacitors through the motor windings. Active discharging is carried out in the event of ignition
01:01:19.188 --> 01:01:24.676
off, in the event of a crash, or pilot line is opened.
01:01:24.676 --> 01:01:32.068
In the event of a defective inverter an emergency compasser discharge is carried out using
01:01:32.068 --> 01:01:34.760
discharge resistors which takes about 4 seconds.
01:01:34.760 --> 01:01:39.897
In passive it's implemented with the aid of various receptorers within the power and --
01:01:39.897 --> 01:01:44.769
resistors between the power and control electronics between the high voltage positive and high
01:01:44.769 --> 01:01:50.159
voltage negative this takes about 120 seconds and is always carried out.
01:01:50.159 --> 01:02:00.832
Charging hybrid and electric vehicles at home. But national infrastructures are developing
01:02:00.832 --> 01:02:06.373
there are however competing organizations and commercial companies so it is necessary to register
01:02:06.373 --> 01:02:10.610
with a few different organizations to access their charging points.
01:02:10.610 --> 01:02:16.534
Many businesses now also provide charging stations for staff and visitors. Some are pay in
01:02:16.534 --> 01:02:19.605
advance. And some are pay as you go.
01:02:19.605 --> 01:02:22.353
And some require monthly subscriptions.
01:02:22.353 --> 01:02:25.932
Many apps and websites are available for locating charging ports.
01:02:25.932 --> 01:02:35.502
One of the best that I have found is located on the screen.
01:02:35.502 --> 01:02:40.248
How long it takes to charge an electric vehicle depends on the type of vehicle, how discharged
01:02:40.248 --> 01:02:44.339
the battery is and the type of ChargePoint used.
01:02:44.339 --> 01:02:49.807
Typically pure electric cars use standard charging will take between six to eight hours to
01:02:49.807 --> 01:02:56.952
fully charge and can be quote opportunity charged whenever possible to keep the battery toped up.
01:02:56.952 --> 01:03:02.171
Pure electric vehicles capable of using rapid charge points can be charged in as little as 30
01:03:02.171 --> 01:03:07.241
minutes and can be toped up in 20 minutes. Depending on the type of charging point and the
01:03:07.241 --> 01:03:09.676
available power.
01:03:09.676 --> 01:03:16.310
Plug-in hybrids take approximately 2 hours to charge from a standard electrical supply.
01:03:16.310 --> 01:03:23.032
And electric REVs take approximately 4 hours to charge from a standard electric supply.
01:03:23.032 --> 01:03:34.405
Both plug-ins and e-rev require less time to charge because their batteries are smaller.
01:03:34.405 --> 01:03:38.937
So that electric vehicles can be charged everywhere with no connection problems, it was
01:03:38.937 --> 01:03:45.948
necessary to standardize charging cables, sockets and methods.
01:03:45.948 --> 01:03:51.659
Although we will not go into depth with the various types of cables and sockets they can be
01:03:51.659 --> 01:03:57.449
broken into three types. The charging cable is permanently mounted to the vehicle. The charging
01:03:57.449 --> 01:04:02.980
cable is not permanently connected to the vehicle or the charging station. Or the charging cable
01:04:02.980 --> 01:04:11.061
is permanently mounted to the charging station.
01:04:11.061 --> 01:04:16.444
Range anxiety continues to be an issue to electric vehicle acceptance. Wireless power
01:04:16.444 --> 01:04:21.792
transfer is a means to increase the range of an electric vehicle without substantially impacting
01:04:21.792 --> 01:04:29.347
the weight or cost. Wireless power transfer is an innovative system for wirelessly charging the
01:04:29.347 --> 01:04:35.836
batteries in electric vehicles. There are three categories. The stationary where the vehicle is
01:04:35.836 --> 01:04:41.856
parked and no driver is in the vehicle. The quasi dynamic where the vehicle is stopped and the
01:04:41.856 --> 01:04:48.541
driver is in a vehicle. And dynamic where the vehicle is in motion.
01:04:48.541 --> 01:04:55.060
With stationary charging, the electric energy is transferred to a parked vehicle. It's
01:04:55.060 --> 01:05:02.260
important to keep the geometrical alignment of primary and secondary within certain tolerance
01:05:02.260 --> 01:05:06.737
values hence a stationary vehicle without a driver.
01:05:06.737 --> 01:05:14.022
In this cause the driver simply parks the vehicle over an induction pad and charging commences
01:05:14.022 --> 01:05:19.609
automatically this type of charging requires no charging poles or associated cabling.
01:05:19.609 --> 01:05:28.275
With quasi dynamic wireless charging the energy is transferred from the roadside primary coil
01:05:28.275 --> 01:05:36.447
system of limited length to the secondary coil of a slow moving in or stop and go mode moving
01:05:36.447 --> 01:05:36.852
vehicle.
01:05:36.852 --> 01:05:42.744
With dynamic wireless charging, the energy is transferred via a special driving lane equipped
01:05:42.744 --> 01:05:50.574
with a primary coil system at high power levels to the secondary coil of a vehicle moving at
01:05:50.574 --> 01:05:53.047
medium to high velocity.
01:05:53.047 --> 01:05:58.434
These wireless charging systems work that range in adverse conditions including extreme
01:05:58.434 --> 01:06:04.235
temperature while being submerged in water, covered with ice or snow. And will operate under
01:06:04.235 --> 01:06:17.859
asphalt or embedded in concrete and is also unaffected by dust or harsh chemicals.
01:06:17.859 --> 01:06:22.256
So let's take a second to talk about Section 301 investigations.
01:06:22.256 --> 01:06:26.941
Currently the United States is working towards a more fair and reciprocal trade relationship
01:06:26.941 --> 01:06:28.417
with China.
01:06:28.417 --> 01:06:34.963
The United States is taking action to confront China over its state-led market distorting
01:06:34.963 --> 01:06:42.352
practices and policies, forced technologies and transfers intellectual property practices and
01:06:42.352 --> 01:06:49.631
cyber intrusions of commercial networks the goal is to look into Chinese mercantilist practices
01:06:49.631 --> 01:06:53.929
change China's behavior and create a level playing field that will give all Americans a better
01:06:53.929 --> 01:06:58.596
chance to succeed.
01:06:58.596 --> 01:07:06.941
Under Section 301 of the Trade Act of 1974 the United States Trade Representative initiated an
01:07:06.941 --> 01:07:12.038
investigation to determine whether China's acts, policies and practices related to technology
01:07:12.038 --> 01:07:16.823
transfer, intellectual property property and innovation are unreasonable or discriminatory and
01:07:16.823 --> 01:07:18.507
burden and restrict U.S. commerce.
01:07:18.507 --> 01:07:29.398
The U.S. trade helps held a private hearing in October of 2019. They consulted with -- in
01:07:29.398 --> 01:07:34.885
2017 consulted with private sector Advisory Committees held two rounds of public comment periods
01:07:34.885 --> 01:07:39.717
and received approximately 70 written submissions from trade associations, U.S. companies, workers,
01:07:39.717 --> 01:07:43.658
academics, think tanks and law firms .
01:07:43.658 --> 01:07:52.299
Following a thorough analysis of available evidence, the USTR with the assistance of the
01:07:52.299 --> 01:07:56.239
interagency station 301 committee determined that numerous acts policies and practices of the
01:07:56.239 --> 01:08:01.568
Government of China related to technology transfer, intellectual property and innovation were
01:08:01.568 --> 01:08:08.075
unreasonable or discriminatory and burdened or restricted U.S. commerce. Specifically the USTR
01:08:08.075 --> 01:08:14.273
found that China used joint venture environments, foreign investment restrictions and
01:08:14.273 --> 01:08:21.381
administrative review and licensing processes to require or pressure technology transfer from U.S.
01:08:21.381 --> 01:08:26.752
companies. That China deprives U.S. companies of the ability to set market-based terms in
01:08:26.752 --> 01:08:30.313
licensing and other technology-related negotiations.
01:08:30.313 --> 01:08:36.579
That China directed an unfairly -- and unfairly facilitated the systematic investment in and
01:08:36.579 --> 01:08:41.173
acquisition of U.S. companies and assets to generate large-scale technological transfer.
01:08:41.173 --> 01:08:46.459
And that China conducted and supported cyber intrusions into U.S. commercial computer networks
01:08:46.459 --> 01:08:51.842
to gain unauthorized access to commercially-valuable business information.
01:08:51.842 --> 01:09:00.933
An interagency team of Subject Matter Experts and economists estimated based on a three-year
01:09:00.933 --> 01:09:06.263
annual average that U.S. damages of $50 billion annually from China's unfair acts policies and
01:09:06.263 --> 01:09:07.006
practices.
01:09:07.006 --> 01:09:14.022
Based on this investigation findings and the interagency consultations, the USTR developed
01:09:14.022 --> 01:09:19.630
recommendations for responsive action to China's unfair trade practices.
01:09:19.630 --> 01:09:32.711
Here are some final words on the 301 investigation.
01:09:32.711 --> 01:09:39.593
Under Section 301 of the Trade Act of 1974 the USTR has broad authority for a range of
01:09:39.593 --> 01:09:44.207
possible responsive actions to meet the goal of eliminating or otherwise resolving these unfair
01:09:44.207 --> 01:09:49.681
practices, such as the imposition of duties or other restrictions on goods or services.
01:09:49.681 --> 01:09:55.929
The USTR has determined that appropriate actions for addressing China's unreasonable or
01:09:55.929 --> 01:09:58.779
discriminatory acts include the following.
01:09:58.779 --> 01:10:07.525
A 25% ad valorem duty in accordance with the President's direction, the USTR has determined to
01:10:07.525 --> 01:10:12.922
impose an additional 25% tariff on $50 billion of product from China that was strategically
01:10:12.922 --> 01:10:19.532
important to and benefited from the made in China 2025 program and other Chinese industrial
01:10:19.532 --> 01:10:20.626
policies.
01:10:20.626 --> 01:10:27.533
The WTO case is where the USTR is pursuing dispute settlements at the World Trade Organization
01:10:27.533 --> 01:10:30.911
to address China's discriminatory licensing practices.
01:10:30.911 --> 01:10:40.084
The United States hopes to work with other like-minded countries in pursuing this case.
01:10:40.084 --> 01:10:45.325
Based on the evidence uncovered in the Section 301 investigation, the President directed the
01:10:45.325 --> 01:10:49.455
Department of Treasury to address concerns about Chinese investments in certain
01:10:49.455 --> 01:10:55.656
technology-intensive sectors. USTR is working closely with the Treasury Department and other
01:10:55.656 --> 01:10:57.886
agencies on this issue.
01:10:57.886 --> 01:11:03.391
These actions will best position the United States to defend the U.S. innovation from unfair
01:11:03.391 --> 01:11:09.613
trade practices and to achieve greater fairness and reciprocity in the United States' trade
01:11:09.613 --> 01:11:15.823
relations with China.
01:11:15.823 --> 01:11:23.096
On September 27th, 2019, the Office of Trade Representative announced the 301 tariff
01:11:23.096 --> 01:11:38.053
exemptions list. A new tariff Note 2V to Subchapter 3 of Chapter 99, 9903.8867 which is now 9903
01:11:38.053 --> 01:11:45.269
.8867 was implemented as set out in the annexes to the Federal Register Notice product exclusions
01:11:45.269 --> 01:11:55.842
were reflected in specified by the prepared product descriptions which included, motorcycles with
01:11:55.842 --> 01:12:00.338
electric power with propulsion each with a power not exceeding 1,000 watts described in
01:12:00.338 --> 01:12:14.053
statistical reporting No. 8711.60.0050 or 8711.60.0090 but what do we mean by motorcycles with
01:12:14.053 --> 01:12:17.927
electric power for propulsion are we only talking about what we would consider a traditional
01:12:17.927 --> 01:12:19.290
motorcycle? No.
01:12:19.290 --> 01:12:27.334
Although the term motorcycle was not defined in the HTS U.S., the term of 8711 suggests a
01:12:27.334 --> 01:12:35.300
broad range of vehicles that include motor bikes, mopeds and other similar vehicles that are not
01:12:35.300 --> 01:12:37.061
conventional motorcycles.
01:12:37.061 --> 01:12:43.377
For example vehicles where the driver is seated. When tariff terms are not defined by the HTS
01:12:43.377 --> 01:12:48.949
U.S. or the explanatory notes, they are construed with the common and commercial meaning.
01:12:48.949 --> 01:12:55.654
According to common definition, a motorcycle is a two wheeled motorized vehicle where the two
01:12:55.654 --> 01:13:00.380
wheels are not side by side but in line.
01:13:00.380 --> 01:13:07.617
Additionally, the explanatory notes to 8711 suggests there is no need for further
01:13:07.617 --> 01:13:12.892
differentiation between conventional and non-conventional types of motorcycles.
01:13:12.892 --> 01:13:20.265
They state, this heading also covers two wheeled electricly powered transportation devices
01:13:20.265 --> 01:13:25.329
designed for carrying a single person for use within low speed areas such as pavements, sidewalks,
01:13:25.329 --> 01:13:27.798
paths and bicycle lanes.
01:13:27.798 --> 01:13:33.661
Their technology allows the driver to stand upright while a system comprised of gyro scopic
01:13:33.661 --> 01:13:44.916
sensors and multiple onboard microprocessors maintain both the vehicle the balancers and riders on
01:13:44.916 --> 01:13:47.989
devices balanced on two independent non-tandem wheels.
01:13:47.989 --> 01:13:53.058
Motorcycles of this heading which are propelled by one or more electric motors are simply known
01:13:53.058 --> 01:13:55.006
as electric motorcycles.
01:13:55.006 --> 01:14:01.112
These motorcycles incorporate an electric accumulateer pack supplying power to the electric
01:14:01.112 --> 01:14:02.178
motor.
01:14:02.178 --> 01:14:08.131
The electric accumulateers of these plug-in type motorcycles can be recharged by plugging them
01:14:08.131 --> 01:14:12.148
into an electric power grid outlet or power station.
01:14:12.148 --> 01:14:17.636
There is a type of electric bicycle that is not covered by the 301 exemption.
01:14:17.636 --> 01:14:26.025
Pedal safety without a separate handlebar -- pedal assist without a separate handlebar
01:14:26.025 --> 01:14:32.000
throttle. This is assistance di bun the rider this assistance can be adjusted from minimal
01:14:32.000 --> 01:14:39.413
assistance to what I have been told is close or adequate 100% self-propulsion. Pedal assist is
01:14:39.413 --> 01:14:42.183
just that. Pedal assist .
01:14:42.183 --> 01:14:50.654
When the rider stops pedaling the bike the bike goes into coasting mode. There is no electric
01:14:50.654 --> 01:14:56.411
propulsion like we discussed when we looked at mild hybrids, these pedal assists are classified as
01:14:56.411 --> 01:15:00.494
electric bicycles. They are just not permitted the exemption.
01:15:00.494 --> 01:15:06.947
Some electric bicycles are equipped with both pedal assist and a throttle which allows the
01:15:06.947 --> 01:15:09.450
electric propulsion without pedaling.
01:15:09.450 --> 01:15:15.900
These bicycles are under the exemption and would be allowed the modified tariff rate.
01:15:15.900 --> 01:15:26.377
Sometimes interesting vehicles pass by our desk that defies normal expectations.
01:15:26.377 --> 01:15:33.065
In August of 2006, the following landed on my desk. At the time of import, the importer
01:15:33.065 --> 01:15:46.335
claimed that the article was the chassis of a World War II cobervagen -- a Kuberwagen was
01:15:46.335 --> 01:15:55.699
designed by Ferdinand Porsche and built by Volkswagen during World War II for use by the German
01:15:55.699 --> 01:16:02.743
military like the Beatles he will it was prototyped as type 62 but eventually became known
01:16:02.743 --> 01:16:09.684
internally as the Type 82. After additional research and consulting with a former U.S. Army
01:16:09.684 --> 01:16:17.778
field Gunner it was determined that the chassis was in fact two model 1937 45 millimeter anti-tank
01:16:17.778 --> 01:16:23.036
guns which had been positioned barrel to barrel to appear to be a wheeled chassis.
01:16:23.036 --> 01:16:33.989
The model 1937 45 millimeter anti-tank gun was nicknamed the little 45. The model 1937 was a
01:16:33.989 --> 01:16:41.324
light quick firing anti-tank gun used in the first stage of the German Soviet war.
01:16:41.324 --> 01:16:52.499
In November of 2017, this office received a request for a ruling on a Soviet era GAZ-71
01:16:52.499 --> 01:16:57.848
amphibious vehicle that the importer wished to use on a hunting preserve although the vehicle did
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not possess a weapon system it was still determined to be classified as a Type 7 munition by the
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bureau of alcohol tobacco firearms and explosives and required not only permission from ATF but
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the Department of State under the statute of international traffic and arms regulations or ITAR.
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As you can guess this vehicle was ultimately not imported .
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So we have reached the end of our presentation.
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And I will now take any questions that you guys have. I will try to answer them all. If I
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cannot answer them, please feel free to email me.
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My contact information is here.
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And I will try to get back to you with an answer.
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>> Three questions came into the meeting chat during the presentation.
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I'll read each one.
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>> Okay.
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>> The first one, are trucks under 8704.2211 imported into the USA exported and assembled from
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Mexico with steel and aluminum from Japan not eligible for USMCA? And at 4% duty. Subject to the
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25% chicken tax in addition to the duty.
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>> Okay. In order for you to -- okay. For USMCA claims, you would still need to follow all the
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rules for USMCA.
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So it would still need to meet the labor. It would still need to meet the aluminum steel.
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And it would still need to meet all the other requirements.
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It would not be subject to the chicken tax.
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The chicken tax is for vehicles that are not coming in from what was NAFTA and which now is
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USMCA. But it would still need to meet all of the steel aluminum requirements.
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The value breakdown.
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And the labor. .
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>> Okay. Excellent.
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A second question for Ruling N287720, can you explain why are the electric pickup trucks
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classified under 8704.90 instead of 8704.60 with only an electric motor for propulsion?
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>> Okay. I would have to take another look at the ruling.
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There was a time when these rulings were written that there was not a specific breakout for
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electric vehicles.
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The specific breakouts for electric vehicles is kind of relatively new.
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So there may not have been a specific breakout. I would need to look.
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It may just have been a provision of other, other, other, other, other.
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Because it wasn't powered by -- it wasn't powered by gas and it wanted powered by diesel so it
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would have had to go into the other.
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So I believe that in that particular ruling, the electric breakout where it was powered solely
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by electric was not in effect at that point.
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>> Excellent.
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Okay. The third question, how do we differentiate between Heading 8709 and headings in 8427?
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>> Okay. Okay.
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8709 is work trucks not fitted with lifting and handling.
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That's -- that is important.
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Not fitted with lifting and handling.
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So if it has any apparatus that allows it to self-load, it does not go into 8709. 8709 is
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simply for those -- the types of vehicles that are used to move cargo around.
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But they cannot lift or handle.
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We had a case where there were these very, very, very large articles called self-propelled
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module transports.
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Some of them were 16 axles. Some of them were 30 axles.
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They can be connected in tandem to be 200 axles.
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And they were designed to move the space shuttle, spacecraft, entire factories. Gigantic
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mining equipment, gigantic electrical transformers.
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They held multiple metric tons were axle. They are gigantic.
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I initially classified them in 8704 as being motor vehicles for the transportation of goods.
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Because they could, in fact, if used in small enough numbers, like single, they could be used on
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public roads.
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Now, obviously if you have four or five of these and you're holding like an entire petroleum
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refinery on top of it and you're moving it into a location, it will, you know, crush the road.
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But it could drive on public roads.
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Headquarters disagreed with me. And they were aiming towards 8709 as being a work truck.
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But then I pointed out that the entire purpose of these things is that they would drive
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underneath the cargo in some cases literally an entire Petro refinery.
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And then they would raise up, lift the article all of the ground in order for them to drive.
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So as much as I really thought that the 8704 was really the appropriate heading, they opted to
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put it into not 8709 but into the 84 I think 27 which is work trucks fitted with lifting and
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handling.
01:23:05.159 --> 01:23:05.496

01:23:05.496 --> 01:23:10.269
Sew it's the lifting and handling that really -- so it's the lifting and handling that really
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makes the difference.
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>> Okay. There are a couple other questions that are continuing to come in. What countries does
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the chicken tax apply?
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>> Everything that's not Mexico and Canada.
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>> Okay. Easy enough.
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>> As far as I understand, it was initiated I believe in 1963 by Lyndon Johnson. It was really
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against Europe.
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So it's really any country that's not -- that we don't have a trade agreement with,
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specifically giving them a special program indicator.
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So the special program indicator for NAFTA, USMCA, would remove the additional duties.
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I mean, so they will still come in -- if they are 8704, they are still going to be 25%. I
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mean, that's just the way it is.
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But if they get the USMCA then they would get the duty-free treatment that they would have
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under NAFTA and then they wouldn't have to pay it. But it's still going to be classified. They
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would just get the reduction.
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>> Okay. And are kei, k-e-i trucks considered a vehicle for transport or passenger?
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>> Okay. That is a great question and I wish I could give you a great definitive answer.
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We are right now fighting in the court. And we're fighting in the harmonized systems
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committee. Regarding these vehicles.
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They have been in the past when they were very, very rare and they were very -- they were a
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novelty item, they weren't really coming in a lot, it was very few of them. They were classified
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in 8709. They are not 8709 vehicles. I mean, you see them -- the whole point -- the first thing
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of 8709, one of the prerequisites is cannot be used on public roads.
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These things are all over the place.
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In my neighborhood alone, I've seen two or three of them that are with license plates that are
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used by small businesses, house cleaners, painters, plumbers. They are small pickup trucks.
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And right now we're fighting to have them definitively classified in the international
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community in 8704.
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So if I get a kei truck I'm going to put it in 8704. And then they can just fight with me
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over it. Because I can't misclassify things. Just because, you know, someone 20 years ago
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misclassified something.
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>> Okay. And one that just came in, I think this is just a request for a previous answer again.
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Does every country other than USMCA and SPI FTA countries subject to the chicken tax?
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01:26:10.810 --> 01:26:17.396
>> As far as I know, yes. I mean, there's -- I mean, honestly, you really have to look at where
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the vehicle is built.
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It has to be built in that country. It can't just come from -- so if you had a vehicle that
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was built in the United States, and it's -- well, here, here is a perfect example.
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Is the Ford transit. So the Ford transit is a -- Ford is a U.S. company . They were building
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the Ford in Turkey.
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So it's an American company.
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And there's no special program for them.
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So the vehicles were going to be classified either in 8703 or 8704.
01:26:53.724 --> 01:27:00.407
In the case of the Transit vans, they got -- the tran sis vans they got caught basically
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disguiseing cargo vans as passenger vans.
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As I had mentioned, anyone -- any import specialist could have walked into a field of 500 of
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these vehicles Fresh Off the Boat and could have with unering accuracy pointed out exactly which
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ones were going to be cargo vans because they didn't have the same equipments. They did not have
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speakers, they were missing the air vents which were standard equipment so you could have just
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picked out which ones were which.
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All those vehicles, even though it was an American company they were built in Turkey they were
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not entitled to any sort of special program and they were hit with the 25% tax.
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So as far as I know, unless there's a special program, I don't know if -- I don't know if like
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a GOWA or any of those Free Trade Agreements are in Chapter 87 because it's been a long time since
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I have seen any vehicle that wasn't coming from Germany or Italy or something.
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But yeah, any vehicle coming from China, from Japan, Germany, Italy, the UK, if it is a
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vehicle for the transportation of goods, it's going to get hit with the chicken tax.
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It's called the chicken tax. But it's a -- it's not a Column 3, it's a Column 1.
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I mean, the duty rate on 8704 for vehicles for the transportation of goods is 25%.
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I mean, it's called the chicken tax because 8703, which is passenger vehicles, is 2.5%.
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Up and down the line.
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And only in a couple of instances for like dumpers or bodies for dumpers or you know those
01:28:48.097 --> 01:28:57.726
types of vehicles where it's 4%, all vehicles in Chapter 8704 are 25% or predominantly are 25%.
01:28:57.726 --> 01:28:59.474
So I call it the chicken tax.
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But that's just the generate of duty on 8704.
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>> Got ya.
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Okay. And a question came in on the slide containing contact information. That should be on
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the screen right now.
01:29:12.436 --> 01:29:15.993
For the person that just asked that question.
01:29:15.993 --> 01:29:16.933
>> Yeah.
01:29:16.933 --> 01:29:26.737
>> So that's Matthew's email address as well as Walter's.
01:29:26.737 --> 01:29:30.919
Okay. I think we're right up to the moment.
01:29:30.919 --> 01:29:38.321
>> Okay. Well, again, I'm happy we had so many attendees, thank you for all of the little
01:29:38.321 --> 01:29:43.489
mrawvz. I think this worked out well. -- applauses. I think this worked out well. A lot of you
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contacted me either directly through the C or directly through email requesting the information
01:29:52.193 --> 01:30:02.142
about the hybrids. I tried to be as -- you know, honestly, hybrid technology is a snooze. It's
01:30:02.142 --> 01:30:10.128
exceptionally interesting in practice. Reading books about it is -- it's very dry. And I kind of
01:30:10.128 --> 01:30:18.184
hope that I brought some information that didn't just, you know, draw your brains out. Because it
01:30:18.184 --> 01:30:22.334
is important, hybrids and electric vehicles are here to stay, they are not going anywhere. They
01:30:22.334 --> 01:30:29.466
are going to become more prevalent. You're going to see less internal combustion engines and
01:30:29.466 --> 01:30:30.245
more electric vehicles.
01:30:30.245 --> 01:30:37.952
So I think that it's important that you guys in the fields and importers just know about these
01:30:37.952 --> 01:30:43.861
types of vehicles that there's a reason why certain vehicles are going to be -- even though it's
01:30:43.861 --> 01:30:51.583
a hybrid, why certain vehicles are not going to be given the same hybrid consideration, especially
01:30:51.583 --> 01:30:58.981
in the 301. Why they are not going to be considered hybrids. And they are going to be classified
01:30:58.981 --> 01:31:01.291
by the gas engine.
01:31:01.291 --> 01:31:06.966
Or other places.
01:31:06.966 --> 01:31:14.015
Are there any other last-minute questions before we close out the 2022 vehicles of 87 and
01:31:14.015 --> 01:31:23.854
saying hello to hybrids?
01:31:23.854 --> 01:31:29.089
Okay. Well, thank you all for your attention. I hope that this was as pleasant for you as it
01:31:29.089 --> 01:31:31.775
was for me. I had a lot of fun putting it together.
01:31:31.775 --> 01:31:38.602
And again, if you guys have any specific questions, my email is right there on the screen.
01:31:38.602 --> 01:31:46.227
So is my phone number. But due to the conditions in New York, I'm not always in my office.
01:31:46.227 --> 01:31:52.413
But I do try to check my voicemail on a daily basis. But the easiest way to get me is to just send
01:31:52.413 --> 01:31:59.611
me an email. Unless you're an importer. In which case, send in those ruling requests. I love to
01:31:59.611 --> 01:32:02.194
see the new technologies that are out there.
01:32:02.194 --> 01:32:07.406
And I love to, you know, go back and forth with you guys about new cars and new vehicles that
01:32:07.406 --> 01:32:09.729
you guys are intending to import.

01:32:15.196 --> 01:32:15.196