The merchandise under consideration is identified as Electrical Drive Units, Part Numbers HA0001N0 and HA0002N0, which are described as electric drive motor assemblies used in passenger automobiles. Both Electrical Drive Units are comprised of an electric motor, an inverter module, a gearbox, and a specialized housing, while Part Number HA0001N0 also incorporates an oil module and a parking lock. You state that Part Number HA0001N0 has a maximum power output of 250 kW and Part Number HA0002N0 has a maximum power output of 190 kW. The inverter module, which consists of printed circuit board assemblies, IGBT modules, and current sensors, is mounted to the motor and performs multiple functions, to include: converting DC voltage from the vehicle’s onboard electrical system into three-phase AC voltage; converting DC voltage into a modified DC voltage; converting AC voltage into DC voltage (charging the high-voltage batteries) during brake energy recuperation; control of the motor operation; communication with the vehicle’s onboard electrical systems; and actuation of the oil module and parking lock, where applicable. The gearbox serves to transfer the rotational force supplied by the electric motor to the vehicle’s axle as the speed and the torque of the motor’s output are converted via gears and an integrated differential. The specialized housing, which is referred to as the acoustic encapsulation, serves to house the Electric Drive Units and provide acoustic dampening. Lastly, the oil module, for Part Number HA0001N0, consists of a reservoir, pump, filter, heat exchanger, etc. and serves to lubricate and cool the gearbox and cool the electric motor. As described, the Electrical Drive Units consist of multiple apparatus and/or machines that contribute to the overall operation/function of the electric motor. Each of the additional machines described are incorporated into/onto the Electrical Drive Units, such as the inverter, which supplies power to the electric motor, or the oil module, which lubricates and cools the gearbox and motor, etc. However, it is our opinion that each additional machine/apparatus is combined with the electric motor to support the motor’s operation.
[1] Please importantly note that only the relevant portion of the related is displayed above. You may refer to the said customs ruling for the entire ruling explanation.
[1]. https://rulings.cbp.gov/ruling/N322256