Ms. Kathy Trotta
Conair Corporation
150 Milford Road
East Windsor, NJ 08520

RE: The tariff classification of water filtration units and replacement filter from China.

Dear Ms. Trotta:

In your letter dated July 20, 2007 you requested a tariff classification ruling. Descriptive literature was submitted. The items you plan to import are household water filtration units, Model Number WCH-850 and Model Number WCH-950, and a replacement filter, Model Number GF-80. The filtration units are placed on a countertop and are used to filter, store, chill and heat water for consumption. They are housed in a metal outer housing and incorporate a cooling fan, a thermal electric cooling component, cal-rod heating element/thermostats and a power supply cord.

Model Number WCH-850 dispenses cold water, while Model Number WCH-950 dispenses hot and cold water. The cold water feature on both units are identical and use thermoelectric technology while the hot water feature in Model Number WCH-950 uses sealed heater and thermostats to maintain hot water.

The water filtration units are considered composite goods that filter, chill and heat water for consumption. Since it is not possible to determine the principal function as provided in Section XVI Note 3 of the Harmonized Tariff Schedule of the United States (HTSUS), it is necessary to apply General Rule of Interpretation (GRI) 3(c). The water filtration units are to be classified in the heading which occurs last in numerical order among those which equally merit consideration in determining their classification.

The applicable subheading for the water filtration units will be 8516.79.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other electrothermic appliances. The duty rate will be 2.7 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

Your inquiry does not provide enough information for us to give a classification ruling on the replacement filter. Your request for a classification ruling should include a sample as well as a component breakdown of the filter. When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.

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.


Robert B. Swierupski
National Commodity
Specialist Division