CLA-2-84:OT:RR:NC:1:102

Ms. Natividad Castaneda
Danby Products, Ltd.
5070 Whitelaw Road
Guelph, Canada N1H 6Z9

RE: The tariff classification of beer coolers from China.

Dear Ms. Castenada:

In your letter dated August 28, 2013 you requested a tariff classification ruling.

The items under consideration are two styles of beer coolers for household use: Model A, the Base Unit Cooler referred to as Item# DKC146SLDB-1, and Model B, the Compact Keg Cooler referred to as Item# DKC146SLDB. Both of these models contain a condenser, a compressor and evaporator, have a capacity of 146 liters and come with wire shelving for the optional storage of bottles/cans. The only difference between the two coolers is that Model A comes with a sealed off hole to accommodate a beer tap and Model B is imported with a tap kit already installed.

You suggest classification of the Base Unit Cooler (Model A) in subheading 8418.21.0010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for refrigerators, freezers and other refrigerating or freezing equipment, electric or other; heat pumps, other than the air conditioning machines of heading 8415; parts thereof, refrigerators, household type, compression type, having a refrigerated volume of under 184 liters. However, because this model comes with prefabricated holes for the possible addition of a beer tap, it has additional functionality beyond that of an ordinary mini refrigerator. As such, the applicable subheading for the Base Unit Cooler will be 8418.69.0180, HTSUS, which provides for refrigerators, freezers and other refrigerating or freezing equipment, electric or other; heat pumps, other than the air conditioning machines of heading 8415; parts thereof, other refrigerating or freezing equipment; heat pumps, other, other refrigerating or freezing equipment. The rate of duty will be free.

The applicable subheading for the Compact Keg Cooler will be 8418.69.0130, HTSUS, which provides for refrigerators, freezers and other refrigerating or freezing equipment, electric or other; heat pumps, other than the air conditioning machines of heading 8415; parts thereof, other refrigerating or freezing equipment; heat pumps, other, soda fountain and beer dispensing equipment. The 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 Michael M. Volpe at (646) 733-3009.

Sincerely,

Myles B. Harmon
Acting Director
National Commodity Specialist Division