Passenger elevator HTS code 8428.10.0000: U.S. import guide 2026

Classification conclusion

U.S. classification, CBP precedent, duty treatment, accessibility rules and state or local approval for a complete passenger elevator.

What is the U.S. HTS code for a passenger elevator?

For a complete passenger elevator for permanent installation in a building, consisting of a car traveling vertically on guide rails with its drive, controls, landing doors and safety system, the appropriate U.S. classification is generally HTSUS 8428.10.0000.

This conclusion does not automatically cover a freight elevator, construction hoist, platform lift, stair lift, escalator, building-escape system, elevator car, controller, traction machine, door system or safety component entered separately.

Why HTSUS 8428.10.0000 applies

GRI 1 places passenger and freight elevators other than continuous-action elevators, together with skip hoists, in subheading 8428.10. A conventional passenger elevator is objectively identified by a car moving between floors on vertical guide rails, normally with a traction or hydraulic drive, landing and car doors, controls and safety devices.

When a complete elevator is shipped unassembled, GRI 2(a) is critical. In CBP ruling NY N300749, an incomplete, unassembled Otis SkyRise elevator from China was classified in 8428.10.0000 because the imported components possessed the essential character of a complete elevator. The ruling shows that packing configuration does not by itself turn an identifiable elevator into unrelated parts.

The opposite boundary is equally important. In NY R02275, CBP declined to classify an external building-escape rescue system as an elevator because it did not have the tariff meaning of a passenger or freight elevator. Separately imported elevator components can also fall in heading 8431 or in their own material/function headings. NY G85976, for example, classified an infrared elevator-door protection system as an elevator part rather than a complete elevator.

Decision boundaries for common elevator imports

The commercial invoice should identify the elevator type, rated load, number of passengers, speed, travel, stops, drive technology and whether all major components are included. “Elevator parts” is not a defensible description for a shipment claimed as a complete elevator under GRI 2(a).

Duty, fees and trade-remedy review

The general duty rate for 8428.10.0000 is Free, subject to verification in the current USITC Harmonized Tariff Schedule.

A free general rate does not establish the total entry liability:

• Merchandise Processing Fee (MPF): applies to formal entries at the current statutory rate, minimum and maximum unless an applicable preference eliminates it.
• Harbor Maintenance Fee (HMF): generally applies to ocean imports, not air freight.
• Section 301: elevators of China origin have historically appeared in Section 301 machinery actions. Use the USTR product search with the 8-digit subheading and confirm the applicable Chapter 99 number, rate and exclusion status on the entry date.
• AD/CVD: no conclusion should be drawn from the HTS number alone. Review Commerce order scope language for elevator systems and separately entered steel, aluminum or electrical components, together with origin and producer/exporter facts.
• Section 232: a complete elevator classified in heading 8428 is not automatically a steel or aluminum article subject to Section 232, but separately entered components can require their own analysis.

The importer of record remains responsible for reasonable care under 19 U.S.C. §1484. Country of shipment is not necessarily country of origin, particularly where cars, controllers, traction machines and doors are produced in different countries and assembled elsewhere.

Import admissibility and installed-elevator compliance

CBP does not generally issue a federal import license solely because a new article is a passenger elevator. Import clearance and permission to install or operate are separate questions.

Building code and safety code

Passenger-elevator installation is primarily controlled through state and local elevator laws, the adopted building code and the authority having jurisdiction. The project team should confirm:

• The edition of ASME A17.1/CSA B44 adopted by the state or locality.
• Installation permits, plan review and licensed elevator-contractor requirements.
• Acceptance inspection and certificate to operate before passenger service.
• Periodic inspection, testing, maintenance-control program and alteration permits.
• Fire-service operation, emergency power, two-way communication and seismic provisions applicable to the project.

ADA accessibility

The U.S. Access Board ADA Standards require passenger elevators serving an accessible route to comply with §407 and the incorporated ASME A17.1 provisions. Relevant features include automatic operation, car dimensions, door clearances, reopening devices, call controls, audible/visible signals, tactile floor designations, Braille and emergency communication.

A freight elevator cannot ordinarily be used as the required accessible passenger route. A limited-use/limited-application elevator, private-residence elevator or platform lift is subject to a different ADA provision and should not be represented as a standard §407 passenger elevator without confirming the permitted application.

Installation safety and other federal issues

• OSHA construction and workplace rules apply to installation, maintenance and employee exposure; state elevator programs may be more specific.
• Wireless emergency, cellular or remote-monitoring equipment may require FCC equipment authorization.
• Origin marking under 19 U.S.C. §1304 and 19 C.F.R. Part 134 must be addressed for the elevator or its container.
• Importers should maintain forced-labor due-diligence records for metals, electronics and upstream supply chains, particularly for China-linked production.

These requirements do not change the tariff number, but they can prevent lawful installation or operation after customs release.

Entry and project records to retain

1. Master equipment schedule identifying elevator model, rated load, persons, speed, travel and stops. 2. Drawings showing car, guide rails, counterweight, traction or hydraulic drive, landing doors and controls. 3. Packing list cross-referenced to every major system component. 4. Contract establishing that the shipment is a complete elevator system, even if unassembled. 5. Bill of materials and manufacturing flow supporting country of origin. 6. ASME compliance documentation, testing records and labels required by the local authority. 7. State/local plan approval, installation permit, acceptance inspection and operating certificate. 8. FCC records for wireless modules and supply-chain evidence for forced-labor review where relevant.

Suggested entry description: “New unassembled automatic passenger elevator system for permanent building installation, model ..., rated load ... kg/... persons, speed ... m/s, ... stops, traction/hydraulic drive, complete with car, guide system, doors, controls and safety equipment.”

Primary authorities and rulings

• U.S. International Trade Commission — Harmonized Tariff Schedule of the United States
• U.S. Customs and Border Protection — NY N300749, incomplete unassembled elevator classified under GRI 2(a)
• U.S. Customs and Border Protection — NY R02275, building-escape system distinguished from an elevator
• U.S. Customs and Border Protection — NY G85976, separately entered elevator-door protection system
• U.S. Access Board — ADA Accessibility Standards, passenger elevators under §407
• Office of the U.S. Trade Representative — Section 301 product search

Professional conclusion

HTSUS 8428.10.0000 is well supported for a complete passenger elevator imported assembled or as an unassembled set possessing the essential character of the finished elevator. The conclusion should not be stretched to a shipment of selected components merely because those components will eventually be installed in an elevator project.

Customs release, code compliance and permission to operate are three different gates. A defensible project addresses all three: tariff classification and origin at entry, state/local installation approval, and final safety/accessibility inspection before passengers are carried.

2026 U.S. customs and import-law review

Legal review date: September 5, 2026. The USITC online HTSUS identified 2026 Revision 18 on this review date. Rates and Chapter 99 measures can change during the year, so the legally operative schedule is the edition in effect on the entry date.

1. Quick legal conclusion

The proposed reporting number is 8428100000 for Lifts and skip hoists, but only for merchandise that matches this defined scope: A complete new automatic passenger elevator for permanent building installation, with a car moving vertically on guide rails, drive, controls, landing and car doors, and safety devices. This is a fact-dependent classification opinion, not a CBP ruling and not a determination of admissibility, origin or AD/CVD scope.

2. Facts that must be verified before entry

• Rated load, passenger capacity, speed and number of stops
• Traction, hydraulic or other drive system
• Complete-system component schedule and shipment configuration

Also obtain the complete bill of materials, technical drawings, model numbers, operating manual, condition and configuration as imported, transaction chain, manufacturer/producer, country of origin of material inputs and intended U.S. use. A material difference requires a new analysis.

3. HTSUS analysis and controlling authority

• GRI 1 places lifts in heading 8428; GRI 6 selects the national passenger-elevator tariff line.
• GRI 2(a) can treat an unassembled shipment as the complete elevator when the imported set already has its essential character.

The analysis must begin with GRI 1, the heading text and binding Section/Chapter Notes, then proceed to GRI 2–5 only if legally necessary and to GRI 6 for subheadings. U.S. Additional Rules of Interpretation and Additional U.S. Notes are controlling where applicable. WCO Explanatory Notes are persuasive interpretive material but are not U.S. statutory text. A CROSS ruling is binding only for the requester and merchandise covered by its facts; materially similar rulings may be persuasive. CIT and Federal Circuit decisions control within their jurisdiction.

Goods outside this opinion include:

• Freight lifts, hospital lifts with materially different specifications, home lifts, construction hoists, platform lifts, escalators and separately imported parts require separate analysis.

For recurring or high-value entries, request a prospective binding ruling from CBP under 19 CFR Part 177 and disclose all material facts. A ruling request is not a substitute for checking post-ruling HTSUS amendments or trade remedies.

4. Duty, fee and tax matrix

This table does not calculate landed cost. The importer must also determine customs value under 19 U.S.C. 1401a, including assists, packing, royalties/license fees, proceeds and related-party acceptability. A “first sale” claim requires a bona fide sale for export to the United States, arm's-length evidence and a complete transaction trail.

5. AD/CVD and evasion review

Do not infer trade-remedy status from the HTS number alone. Screen the country of origin, producer and written scope of every active AD/CVD order, and test any applicable Chapter 99 provision as of the entry date.

The written scope description is dispositive; an HTSUS number in an order is only a convenience reference. If coverage is uncertain, obtain a Commerce scope ruling under 19 CFR 351.225 before relying on a non-covered position. Minor processing or assembly in a third country can trigger a circumvention analysis. False origin, undervaluation or evasion can lead to EAPA investigation under 19 U.S.C. 1517 and civil penalties under 19 U.S.C. 1592.

6. Partner Government Agency and product compliance

Federal tariff classification is not approval to install or operate the elevator. Accessibility design should be checked against the 2010 ADA Standards, including section 407, together with state and local elevator, building, fire and electrical codes.

PGA admissibility is independent of tariff classification. Transmit all required agency data and documents through ACE; a CBP release does not cure a violation of an FDA, CPSC, EPA, FCC, DOT, USDA or other agency rule.

7. Origin, marking and UFLPA

Determine nonpreferential origin under the substantial-transformation test and any product-specific rule; do not rely only on the shipping country, invoice origin or location of final packing. Mark the article and, when required, its container under 19 U.S.C. 1304 and 19 CFR Part 134, unless a documented exception applies. Section 301, AD/CVD, government procurement and a preference program may use distinct origin rules.

Under 19 U.S.C. 1307 and the UFLPA, goods mined, produced or manufactured wholly or in part in Xinjiang, or by an entity on the UFLPA Entity List, are subject to a rebuttable presumption of exclusion. Maintain supplier identity, production, payment, logistics and input-tracing evidence; a generic supplier declaration is not enough for a high-risk supply chain.

8. Minimum entry file

• CBP entry/cargo release data and Form 7501 record, customs bond, commercial invoice, packing list and bill of lading/air waybill.
• Purchase orders, payment records, Incoterms, assists/royalties analysis and related-party or first-sale valuation support.
• Product specifications, drawings, photographs, manuals, composition/BOM, model cross-reference and condition as imported.
• Signed classification memorandum applying the GRIs, legal notes, current HTSUS text and relevant rulings, plus rejected alternatives.
• Origin and marking analysis; producer/supplier affidavits and traceability records; Chapter 99 and exclusion support.
• AD/CVD scope search, producer/exporter case numbers and cash-deposit instructions, even when the conclusion is “not covered.”
• All PGA registrations, certificates, laboratory reports, licenses, notices and ACE data required for this product.

Keep entry and supporting records for the statutory period, generally five years, under 19 U.S.C. 1508 and 19 CFR Part 163.

9. Principal legal risks

• Declaring a 10-digit number from the trade name without proving the imported condition and legally relevant characteristics.
• Omitting a Chapter 99 number or calculating only the Column 1 rate.
• Treating an AD/CVD HTS cross-reference as dispositive instead of reading the written scope.
• Using shipping country as origin without a substantial-transformation and marking analysis.
• Filing before PGA admissibility, certificates, laboratory evidence or supply-chain traceability are complete.

An incorrect entry can produce redelivery, exclusion/seizure, duty reassessment, interest, loss of liquidation defenses and penalties. If past entries contain a material error, promptly evaluate a post-summary correction, protest, prior disclosure under 19 CFR 162.74 or other corrective procedure with U.S. customs counsel; the correct route depends on entry and liquidation status.

10. Pre-entry action checklist

1. Lock the specifications and imported configuration for the exact SKU. 2. Re-run classification against the current HTSUS and record GRI/Note reasoning. 3. Determine customs value, nonpreferential origin and marking. 4. Screen Chapter 99, Section 301/232, quota/safeguard and every potentially relevant AD/CVD scope. 5. Complete the product-specific PGA review and obtain supporting certificates before shipment. 6. Calculate landed duties and fees, then have the importer and licensed customs broker validate ACE reporting. 7. For unresolved or commercially material classification issues, obtain a CBP Part 177 ruling before importation.

Official legal sources

• United States International Trade Commission; HTSUS 2026: Harmonized Tariff Schedule of the United States
• U.S. Customs and Border Protection; NY N300749: Unassembled passenger elevator classified under GRI 2(a) in 8428.10.0000
• U.S. Access Board; 2010 ADA Standards §407: Elevator accessibility requirements
• USITC — Current Harmonized Tariff Schedule of the United States
• CBP — User fee table: MPF rate and FY 2026 minimum/maximum
• CBP — Harbor Maintenance Fee
• CBP — ACE: filing customs and Partner Government Agency data
• USTR — Section 301 tariff actions and exclusion search
• BIS — Section 232 steel and aluminum measures
• Commerce — AD/CVD FAQs, scope and circumvention rules
• Commerce — ACCESS AD/CVD proceeding search
• CBP — UFLPA rebuttable presumption
• CPSC — Certificates and mandatory eFiling guidance
• FDA — Importing food products into the United States
• EPA — TSCA requirements for importing chemicals
• PHMSA — Lithium battery transportation requirements
• FCC — Equipment authorization
• eCFR — 19 CFR Part 177: administrative rulings
• eCFR — 19 CFR Part 134: country-of-origin marking
• eCFR — 19 CFR Part 163: recordkeeping

> Legal notice: This article provides general U.S. customs and trade-compliance information based on the stated facts as of September 5, 2026. It is not a CBP, Commerce or PGA ruling and is not legal advice for a specific transaction. Current HTSUS/Chapter 99 text, agency requirements and case-specific AD/CVD instructions must be rechecked at entry.

Editorial note

Prepared by the Global HS Code Checker Editorial Team for customs-classification, tariff and import-policy research. The correct code and applicable measures may change with the merchandise's actual characteristics, jurisdiction, entry date and supporting record. Verify the current tariff, governing measures and competent customs authority before filing an entry. A reviewer is identified only after a named expert has completed the review.