CLA-2-84:RR:E:NC:N1:106

Mr. Steven Thornley
619 Misty Hill La.
Dallastown, PA 17313

RE: The tariff classification of a solar water heating system from China.

Dear Mr. Thornley:

In your letter dated June 6, 2008 you requested a tariff classification ruling. You included schematic materials and a description with your request. The merchandise at issue is referred to as an ATE M360 solar water heating system. The system is designed to heat water and circulate the heated water to showers or other faucets in a home. The complete system consists of a solar collector panel which receives cool water from the home’s water supply by an included pump. The water in the panel is heated by the sun and then held in the system’s storage tank until used. The water heating unit contains a copper coil as an auxiliary electric heating element. There is an electronic controller included for the system’s operation. Your request indicates that pipes, connectors are not included. It should be noted that any components which are not imported with the complete system would be classifiable based on their own features and not necessarily as a part of the solar water heating system.

The applicable subheading for the ATE M360 solar water heating system will be 8419.19.0040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for machinery,…; instantaneous or storage water heaters, nonelectric;…: other, solar water heaters. The general rate of duty will be free. 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 Mark Palasek at 646-733-3013.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division