NCS/ARS/CL/10436

You have applied for the tariff classification of Solar-Powered Generators (Models S50B and S130) and an Energy Storage System, imported as fully built units.

PRODUCT ANALYSIS

Solar-Powered Generators (Models S50B and S130)

1. Based on the technical documentation submitted, the S50B and S130 are mobile solar-powered energy systems designed to generate, store, and supply electrical energy for domestic and other low-power applications. The systems harness solar energy through photovoltaic (PV) panels, convert the solar energy into electrical energy, and store the generated electricity in an integrated lithium iron phosphate (LiFePO₄) battery for subsequent use.

The systems can provide a continuous supply of electricity for various appliances and electronic devices, including LED lighting, radios, televisions, DC appliances, mobile phones, tablets, and other compatible equipment. The integrated battery storage enables the systems to supply electricity when solar energy is unavailable, such as during nighttime or periods of insufficient sunlight.

The product consists of two principal functional units, namely the outdoor solar panel unit and the indoor energy storage and control unit, which are packed together in the same carton at the time of importation.

According to the technical documentation submitted, the S50B model comprises a 4 Ah main unit, two 11 W photovoltaic (PV) modules, three LED lamps rated at 1 W, 2 W, and 3 W respectively, mounting accessories, a remote control, and three lamp shades.

The S130 model, on the other hand, comprises a 12 Ah main unit, a 50 W, 65 W, or 100 W photovoltaic (PV) module, four 1 W LED lamps, mounting accessories, and four lamp shades.

The components are supplied together as a complete solar-powered energy system and are intended to function in combination to generate, store, control, and supply electrical power to connected appliances and lighting devices.

1. The Energy Storage System (ESS) - Huawei LUNA2000-(107–215) Series 

According to documentation, the Huawei LUNA2000-(107–215) Series is an Energy Storage System (ESS), incorporating battery packs, a Power Conversion System (PCS), DC-DC converter, Rack Control Module (RCM), Liquid Cooling Controller (LCC), monitoring sensors, display module and fire detection and suppression devices, which operate together to store, manage, convert and supply electrical energy.

Based on your submitted document, the Energy Storage System (ESS) consists of the following Components: -

1. Battery Packs – 2/3/4 packs
   Each battery pack consists of multiple battery cells connected in series to form a battery assembly capable of supplying or receiving electrical energy through positive and negative terminals. Each pack incorporates a Battery Management Module (BMS), DC-DC balancing module and liquid cooling plate for battery monitoring, cell balancing and thermal management. 
2. Power Conversion System (PCS) – 1 unit
   The PCS converts the DC electrical energy discharged from the battery system into the specified AC voltage for supply to connected loads. It also converts AC electrical energy into DC for charging the battery system. The PCS supports 100% unbalanced loads. 
3. DC-DC Converter (DCDC) – 1 unit
   The DC-DC converter converts the DC voltage supplied by the battery rack into a stable DC voltage suitable for the required system applications. This function is available only on specified models. 
4. Rack Control Module (RCM) – 1 unit
   The RCM comprises the Battery Control Unit (BCU), rack power control board, fuse, contactors and associated control components. It performs ESS control and monitoring functions, including short-circuit fault detection, insulation monitoring, leakage-current detection, high-precision current measurement, auxiliary power supply and communication/connectivity with the ESS monitoring system or mobile application. 
5. Liquid Cooling Controller (LCC) – 1 unit
   The Liquid Cooling Controller (LCC) regulates the temperature within the ESS cabinet. It controls the cooling, heating and dehumidification functions to maintain the battery system within the required operating conditions. Etc.

TARIFF CLASSIFICATION

Product 1

1. Based on the description and analysis, Product 1 consists of a solar-powered generator system comprising two principal functional units, namely, an outdoor solar panel unit and an indoor energy storage and control unit. It generates, store, regulate, control, and supply electrical power to connected appliances and lighting devices.

Product 1 is available in the following models:

1. S50B model – with an output of 11 W; and
2. S130 model – with an output ranging from 50 W to 100 W.

The Explanatory Notes (EN) to Heading 85.01 provide that the heading covers photovoltaic generators consisting of panels of photocells combined with other apparatus, such as storage batteries and electronic controls (voltage regulators, inverters, etc.), as well as panels or modules equipped with elements, however simple, that supply power directly.

In view of the above, Product 1 falls under Heading 85.01- “Electric motors and generators (excluding generating sets), photovoltaic DC generators, and properly classified as follows:

1. 8501.71.00.00 – Of an output not exceeding 50 W, applicable to the S50B model, at 5% rate of duty and 7.5% VAT; and

    

2. 8501.72.00.00 – Of an output exceeding 50 W, applicable to the S130 model, at 5% rate of duty and 7.5% VAT.

Product 2

1. Considering the provisions of Note 3 to section XVI, and the foregoing analysis, the Battery packs, Power Conversion System, DC-DC converter Liquid Cooling Controller and all other components of this machinery is designed to perform complimentary and alternating functions through the reception, conversion, storage and output of electrical energy when needed.

Note 3 to Section XVI provides that:

“Unless the context otherwise requires, composite machines consisting of two or more machines fitted together to form a whole and other machines designed for the purpose of performing two or more complementary or alternative functions are to be classified as if consisting only of that component or as being that machine which performs the principal function.”

Furthermore, the Explanatory Note to heading 8504, Part II, states inter alia:

“The apparatus of this group (Part II to EN 8504) are used to convert electrical energy in order to adapt it for further use. They incorporate converting elements of different types.”

In view of the foregoing and considering that the machinery is a system for storage and distribution of energy by converting electrical energy within the ESS, the product is appropriately classified under heading 8504, which covers “Electrical transformers, static converters (for example, rectifiers) and inductors,” and effectively classified under tariff subheading 8504.40.90.00 – Static converters, other, attracting a 5% rate of duty and 0% VAT, in line with ECOWAS Common External Tariff (CET) 2022 – 2027

GIR 1& 6

EN to Heading 8501, Part II, paragraph 5.

Note 3 to Section XVI

Part II, to Explanatory Note to Heading 8504