CLA-2-84:RR:NC:N1:102

Ms. Sarah Yoo
LG Electronics USA, Inc.
1000 Sylvan Avenue
Englewood Cliffs, NJ 07632

RE: The tariff classification of VAV packaged heat pumps.

Dear Ms. Yoo:

In your letter dated May 17, 2007 you requested a tariff classification ruling on behalf of LG Electronics.

The items you plan to import are described as water source VAV packaged heat pumps, Model Numbers AKWW0363UD0, AKWW0483UD0 and AKWW0603UD0. The VAV is a reversible heat pump used for heating and cooling in high-rise buildings. The VAV heat pumps use a heat exchange method that employs water.

The applicable subheading for the VAV packaged heat pumps will be 8415.81.0130, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other air conditioning machines incorporating a refrigeration unit and a valve for reversal of the cooling/heat cycle (reversible heat pumps). The rate of duty will be 1 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Kenneth T. Brock at 646-733-3009.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division