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

Ms. Gianna Beireis
Tradewin
1015 3rd Ave
Seattle, WA 98104

RE: The tariff classification of condensers, outdoor components of a heat pump system and a de-humidifier from China

Dear Ms. Beireis:

In your letter dated August 28, 2019 you requested a tariff classification ruling on behalf of your client, Heat Controller LLC. Descriptive information was included with your submission.

Items one and two are referred to as CMA side discharge condensers, part numbers CMA12SD-0 and CMA18SD-1. Each condenser is an outdoor component of an air conditioning system and primarily consists of a chassis, an outer cabinet, a condenser coil, a motor driven fan, and a compressor unit.

Item three is referred to as the outdoor component of a multi-zone mini-split heat pump system, part number A-VFH18DB-1. The outdoor component primarily consists of a chassis, an outer cabinet, a condenser coil, a motor driven fan, and a compressor unit.

Item four is referred as the portable dehumidifier, part number BHD-301-H.  The dehumidifier with a self-contained electric motor rated 115V is a domestic appliance that has a water removal capacity of 30 pints per day. The dehumidifier measures approximately 20.1 inches in height by 14.2 inches in width by 9.9 inches in depth and has a shipping weight of 31 lbs.

The applicable subheading for the CMA side discharge condensers, part numbers CMA12SD-0 and CMA18SD-1, imported separately, will be 8415.90.8085, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Air conditioning machines, comprising a motor-driven fan and elements for changing the temperature and humidity, including those machines in which the humidity cannot be separately regulated: Parts: Other: Other: Other. The general rate of duty is 1.4 percent ad valorem.

The applicable subheading for the outdoor component of a multi-zone mini-split heat pump system, part number A-VFH18DB-1, imported separately, will be 8415.90.8065, HTSUS, which provides for Air conditioning machines, comprising a motor-driven fan and elements for changing the temperature and humidity, including those machines in which the humidity cannot be separately regulated: Parts: Other: Other: Of heat pumps. The general rate of duty is 1.4 percent ad valorem.

The applicable subheading for the portable dehumidifier, part number BHD-301-H, will be 8509.80.5095, HTSUS, which provides for Electromechanical domestic appliances, with self-contained electric motor, other than vacuum cleaners of heading 8508: other appliances: other: other.  The rate of duty will be 4.2 percent ad valorem.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 8415.90.8085 and 8415.90.8065, HTSUS, unless specifically excluded, are subject to an additional 15 percent ad valorem rate of duty.  At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheadings 8415.90.8085 and 8415.90.8065, HTSUS, listed above.   The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. 

For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.

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 the World Wide Web at https://hts.usitc.gov/current.

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 Sandra Martinez at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division